oversight

Federal Protective Service: Better Data on Facility Jurisdictions Needed to Enhance Collaboration with State and Local Law Enforcement

Published by the Government Accountability Office on 2012-03-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to the Ranking Member,
             Committee on Homeland Security,
             House of Representatives


March 2012
             FEDERAL
             PROTECTIVE
             SERVICE
             Better Data on Facility
             Jurisdictions Needed
             to Enhance
             Collaboration with
             State and Local Law
             Enforcement




GAO-12-434
                                              March 2012

                                              FEDERAL PROTECTIVE SERVICE
                                              Better Data on Facility Jurisdictions Needed to
                                              Enhance Collaboration with State and Local Law
                                              Enforcement
Highlights of GAO-12-434, a report to the
Ranking Member, Committee on Homeland
Security, House of Representatives.




Why GAO Did This Study                        What GAO Found
The Department of Homeland                    To collaborate with state and local law enforcement, the Federal Protective
Security's (DHS) Federal Protective           Service (FPS) uses memorandums of understanding (MOU), long-standing
Service (FPS) protects over 9,000             working relationships, written guidance to FPS staff, joint operations, and other
federal facilities under the custody and      initiatives. For example, FPS has MOUs ranging from sharing radio frequency
control of the General Services               usage in Alabama, to a mutual aid agreement with the Metropolitan Atlanta Rapid
Administration (GSA). In 2007, FPS            Transit Authority in Georgia. In some jurisdictions, such as the suburbs of the
adopted an inspector-based workforce          District of Columbia, FPS has no MOUs but has regular contact and long-
approach and indicated it would               standing mutual aid relationships with state and local law enforcement. To
increase its reliance on state and local
                                              collaborate with state and local law enforcement, FPS has guidance that
law enforcement agencies to respond
                                              addresses issues such as the scope of law enforcement authorities on federal
to incidents at these facilities. These
facilities range from facilities of
                                              property and information sharing among jurisdictions. FPS established regional
proprietary or concurrent jurisdiction—       staff positions intended to improve collaboration with other organizations and has
where authority is shared by federal          engaged in joint operations with state and local law enforcement. By comparison,
and state and local police—to facilities      other federal organizations with law enforcement responsibilities similar to FPS
of exclusive jurisdiction, where only         also use a variety of methods, ranging from the Department of Veterans Affairs’
federal law enforcement has authority.        policy to seek MOUs with state and local law enforcement to the Smithsonian
As requested, this report assesses            Institution’s established relationships with the Metropolitan D.C. Police and
FPS’s efforts to collaborate with state       others.
and local law enforcement for
                                              GAO found that state and local law enforcement organizations it contacted are
assistance in responding to incidents
at these federal facilities. GAO              generally willing to assist with incidents at federal facilities. For example, 48 of 52
reviewed documents on collaboration,          respondents from state and local law enforcement agencies GAO contacted
GSA and FPS facility data, and GAO’s          about this issue said that they would respond to a call at a federally owned
work on key collaboration practices           facility; 27 said they had done so since 2007. Overall, the variety of efforts FPS
and internal control standards. GAO           has under way is consistent with the key collaboration practices GAO has
also contacted 73 selected state and          previously identified and reflects a reasonable approach to collaboration,
local law enforcement agencies from           especially when combined with the willingness of state and local law enforcement
geographic jurisdictions of varying           to assist.
population sizes and FPS buildings
throughout the United States and
                                              Although FPS has a reasonable approach to state and local collaboration, GAO
interviewed FPS and GSA officials.            found issues related to the quality of data exchanged between GSA and FPS on
                                              buildings and their locations. Through working groups, GSA is working with FPS
What GAO Recommends                           to address these data inconsistency issues and is establishing a permanent GSA
                                              liaison at FPS’s headquarters to improve data coordination. But as of the end of
In conjunction with the revised MOU           GAO’s review, FPS still lacked complete data from GSA on the jurisdiction of
that is being developed between               about one third of the buildings it protects. GSA officials informed GAO that they
GSA and FPS, GAO recommends                   are making progress with identifying building jurisdictions but were not yet in a
the administrator of GSA ensure that          position to provide complete information to FPS. These data are important
efforts to identify the jurisdictions of      because state and local law enforcement generally has no authority to enforce
all GSA buildings are completed and           state and local law on properties of exclusive federal jurisdiction. An additional
that these data are provided to FPS.          effect of not having these data is that FPS lacks assurance that in relying on
GSA concurred with the                        state and local law enforcement to respond to incidents at federal facilities, it is
recommendation.                               not creating a situation where these entities may be exercising police authority
                                              where they lack such authority. As a result, incomplete jurisdictional data leaves
                                              FPS and state and local law enforcement less equipped to define and agree to
                                              respective roles and responsibilities when there are incidents at federal facilities.
View GAO-12-434. For more information,
contact Mark L. Goldstein at (202) 512-2834
or goldsteinm@gao.gov.

                                                                                        United States Government Accountability Office
Contents


Letter                                                                                     1
               Background                                                                  4
               FPS Uses Various Approaches to Collaborate with State and Local
                 Law Enforcement, but Jurisdictional Data on Federal Facilities
                 Are Incomplete                                                           9
               Conclusions                                                               19
               Recommendations for Executive Action                                      19
               Agency Comments and Our Evaluation                                        19

Appendix I     Objective, Scope and Methodology                                          21



Appendix II    Comments from the General Services Administration                         24



Appendix III   Comments from Department of Homeland Security                             25



Appendix IV    GAO Contact and Staff Acknowledgments                                     27



Tables
               Table 1: State and Local Law Enforcement Agencies’ Responses to
                        Selected Questions in GAO’s Structured Questionnaire
                        Regarding FPS Collaboration                                      14
               Table 2: Jurisdiction of Properties under the Control of GSA with
                        FPS Responsibility                                               16


Figures
               Figure 1: Federal Protective Service MegaCenter, Suitland,
                        Maryland                                                           6
               Figure 2: Notification and Response Actions Following an Incident
                        at an FPS-Protected Facility                                       7




               Page i                                GAO-12-434 Law Enforcement Collaboration
Abbreviations

ADFO              Assistant Director for Field Operations
DHS               Department of Homeland Security
FPS               Federal Protective Service
GSA               General Services Administration
MOU               memorandums of understanding
MPD               Metropolitan Police Department
NPS               National Park Service
SI                Smithsonian Institution
VA                Department of Veterans Affairs
VAMC              Department of Veterans Affairs Medical Centers




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Page ii                                         GAO-12-434 Law Enforcement Collaboration
United States Government Accountability Office
Washington, DC 20548




                                   March 27, 2012

                                   The Honorable Bennie G. Thompson
                                   Ranking Member
                                   Committee on Homeland Security
                                   U.S. House of Representatives

                                   Dear Mr. Thompson:

                                   The Department of Homeland Security’s (DHS) Federal Protective
                                   Service (FPS) protects over 9,000 federal facilities under the custody and
                                   control of the General Services Administration (GSA) by delivering
                                   integrated law enforcement and security services. To secure these
                                   buildings and safeguard their occupants, FPS employs about 1,225
                                   federal staff, including law enforcement officers, investigators, and
                                   administrative personnel, and is responsible for management and
                                   oversight of approximately 14,000 contract security guards. These federal
                                   facilities range from facilities of proprietary or concurrent jurisdiction—in
                                   which authority is shared by federal and state and local police—to
                                   facilities of exclusive jurisdiction in which only federal law enforcement
                                   has authority. FPS conducts its mission by providing security services
                                   through two types of activities: (1) physical security activities, such as
                                   conducting risk assessments of GSA facilities and recommending risk-
                                   based countermeasures to GSA and tenant agencies aimed at reducing
                                   the likelihood and severity of incidents at facilities, and (2) law
                                   enforcement activities, such as responding to incidents, conducting
                                   criminal investigations, and exercising arrest authority. In order for FPS to
                                   track the continuous changes in the inventory of buildings that it
                                   protects—including new construction, disposed buildings, and over 8,000
                                   leases—GSA, through its Public Buildings Service, 1 provides building
                                   data to FPS weekly from GSA’s building property system.




                                   1
                                    The Public Buildings Service acquires space on behalf of the federal government through
                                   new construction and leasing and acts as a caretaker for federal properties across the
                                   country.




                                   Page 1                                        GAO-12-434 Law Enforcement Collaboration
In 2007, FPS adopted an inspector-based workforce approach to protect
GSA-controlled facilities. 2 In testimony to Congress that same year, a
DHS senior official stated that the agency was increasing its reliance on
state and local law enforcement agencies to assist in responding to law
enforcement incidents at these facilities as a way of ensuring that GSA
buildings are adequately protected. 3 While FPS is statutorily responsible
for enforcing federal laws and regulations for the protection of federal
property and persons located on federal property regardless of the
location, state and local law enforcement agencies are responsible for
enforcing state laws and local ordinances within the particular state on
concurrent and proprietary jurisdiction locations. In 2008, we
recommended that FPS clarify roles and responsibilities of local law
enforcement agencies in responding to incidents at GSA-controlled
facilities. 4 Since this report was issued, FPS has issued specific agency
instructions regarding coordination, hired new personnel to oversee
coordination in the regions, and pursued additional memorandums of
understanding (MOU) 5 when needed, such as in the case of clarifying
roles and responsibilities between FPS and state and local law
enforcement.

You asked us to provide an update on these issues. This report assesses
FPS’s efforts to collaborate with state and local law enforcement for
assistance in responding to incidents at federal facilities. To meet this
objective, we reviewed relevant documentation on federal facility building


2
 This model was intended to make more efficient use of FPS’s declining staffing levels by
increasing focus on FPS’s physical security duties and consolidating law enforcement
activities. FPS’s goal was to shift its law enforcement workforce composition from a mix of
about 40 percent police officers, about 50 percent inspectors, and about 10 percent
special agents, to a workforce primarily composed of inspectors and some special agents.
FPS’s inspectors are responsible for law enforcement and security duties, including:
patrolling building perimeters, responding to incidents, completing risk assessments for
buildings, recommending security countermeasures, and overseeing the contract security
workforce.
3
 Hearing on “Proposals to Downsize the Federal Protective Service and Effects on the
Protection of Federal Buildings,” Committee on Transportation and Infrastructure, U. S.
House of Representatives, April 18, 2007.
4
 GAO, Homeland Security: The Federal Protective Service Faces Several Challenges
That Hamper Its Ability to Protect Federal Facilities, GAO-08-683 (Washington, D.C.: June
11, 2008).
5
 For consistency, we are using the term MOU throughout this report for both
memorandums of understanding (MOUs) and memorandums of agreement (MOAs).




Page 2                                          GAO-12-434 Law Enforcement Collaboration
data from GSA. In addition, we emailed a self-administered set of 22
structured questions to the heads of 73 state and local law enforcement
agencies in jurisdictions throughout the United States that we determined
had FPS-protected buildings. Our non-random selection of locations
included varying population sizes served by the state and local law
enforcement agencies located in a mixture of urban and rural areas as
defined by the United States Department of Agriculture. We used the
most recent Rural-Urban Continuum Codes. 6 We followed up our emails
with phone calls to these state and local law enforcement agencies to
obtain clarification of the responses as needed. Not every respondent
answered every question. Although the results of our structured
questionnaires cannot be generalized to the universe of jurisdictions that
interact with FPS, the results provide key insights and illustrate how these
organizations can help FPS respond to incidents.

Further, we interviewed GSA officials at GSA Headquarters in
Washington, D.C. We also interviewed FPS officials at the Suitland,
Maryland, and Battle Creek, Michigan, FPS MegaCenters 7 and toured the
Suitland MegaCenter. We interviewed each of the 11 FPS Regional
Directors to determine how their respective regions coordinate with state
and local law enforcement agencies for the properties in their jurisdiction.
For comparison with FPS, we contacted three federal agencies that
provide their own law enforcement services at their facilities—the
Department of Veterans Affairs, the Department of the Interior’s National
Park Service, and the Smithsonian Institution. We obtained relevant
documents pertaining to their collaboration with state and local law
enforcement and interviewed key officials. Lastly, we reviewed prior GAO
work, including reports on key practices in interagency collaboration,
facility protection, and internal controls. We also reviewed FPS data on
buildings protected, staffing, procedures, and MOUs that are in place and


6
 Rural-Urban Continuum Codes form a classification scheme that distinguishes
metropolitan (metro) counties by the population size of their metro area, and
nonmetropolitan (nonmetro) counties by degree of urbanization and adjacency to a metro
area or areas. See USDA Economic Research Service at
http://www.ers.usda.gov/Briefing/Rurality/RuralUrbCon/.
7
 In 2000, the Federal Protective Service (FPS) transitioned all alarm-monitoring and
dispatching capabilities from several regional control centers to four MegaCenters.
Currently, each MegaCenter monitors multiple types of alarm systems, closed circuit
television, and wireless dispatch communications within federal facilities throughout the
nation. These centers—located in Michigan, Colorado, Pennsylvania, and Maryland—are
equipped with state-of-the-art communication systems and operate continuously.




Page 3                                         GAO-12-434 Law Enforcement Collaboration
             assessed the quality and completeness of these data. Collectively, this
             multifaceted approach enabled us to make conclusions about whether
             FPS’s collaboration approach is reasonable. Appendix I contains more
             information on our objective, scope, and methodology.

             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.


             FPS—located within the National Protection and Programs Directorate 8 of
Background   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. 9 These federal facilities
             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.




             8
              GAO, Federal Protective Service: Progress Made but Improved Schedule and Cost
             Estimate Needed to Complete Transition, GAO-11-554 (Washington, D C.: July 15, 2011).
             9
              Section 1315(a) of Title 40, United States Code, provides that: “To the extent provided for
             by transfers made pursuant to the Homeland Security Act of 2002, the Secretary of
             Homeland Security…shall protect the buildings, grounds, and property that are owned,
             occupied, or secured by the Federal Government (including any agency, instrumentality,
             or wholly owned or mixed-ownership corporation thereof) and the persons on the
             property.”




             Page 4                                          GAO-12-434 Law Enforcement Collaboration
•   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.




Page 5                                   GAO-12-434 Law Enforcement Collaboration
Figure 1: Federal Protective Service MegaCenter, Suitland, Maryland




                                         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.)




                                         Page 6                                GAO-12-434 Law Enforcement Collaboration
Figure 2: Notification and Response Actions Following an Incident at an FPS-Protected Facility




                                         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. 10 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




                                         10
                                          GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain
                                         Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).




                                         Page 7                                      GAO-12-434 Law Enforcement Collaboration
•     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. 11 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. 12
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). 13 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. 14
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


11
  GAO, Homeland Security: Further Actions Needed to Coordinate Federal Agencies’
Facility Protection Efforts and Promote Key Practices, GAO-05-49 (Washington, D.C.:
Nov. 30, 2004).
12
  GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1.
(Washington, D.C.: November 1999).
13
    38 U. S. C. § 902.
14
    16 U. S. C. § 1A-6(b).




Page 8                                        GAO-12-434 Law Enforcement Collaboration
                            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. 15



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   FPS uses a variety of methods to collaborate with state and local law
Variety of MOUs, Reliance   enforcement, ranging from establishing MOUs to document agreement on
on Long-standing            roles and responsibilities with some, to relying on long-standing working
                            relationships with others. FPS also has guidance and various other efforts
Relationships, Guidance,    under way related to coordination with state and local law enforcement.
and Other Initiatives       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. 16 For example, there is an MOU for radio frequency
                            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




                            15
                             40 U. S. C. § 6306.
                            16
                             We did not determine the total universe of state and local law enforcement jurisdictions
                            where FPS-protected properties are located.




                            Page 9                                         GAO-12-434 Law Enforcement Collaboration
leadership, and to establish compatible policies, procedures, and other
means to operate across agency boundaries. 17

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




17
 GAO-06-15.




Page 10                                  GAO-12-434 Law Enforcement Collaboration
task forces, and regional fusion center meetings. 18 Attendance by both
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.




18
  The Federal Executive Boards, established by Presidential Directive in 1961, are a
forum for communication and collaboration among federal agencies outside of
Washington, D.C. Joint terrorism task forces (JTTFs) are small cells of highly trained,
locally based investigators, analysts, linguists, special weapons and tactics experts, and
other specialists from dozens of U.S. law enforcement and intelligence agencies. JTTFs
are used as a multi-agency effort by the U.S. Department of Justice and the Federal
Bureau of Investigation to combine the resources of federal, state, and local law
enforcement. Fusion centers serve as focal points within the state and local environment
for the receipt, analysis, gathering, and sharing of threat-related information between the
federal government and state, local, tribal, territorial, and private sector partners.




Page 11                                         GAO-12-434 Law Enforcement Collaboration
                            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     Other federal organizations with law enforcement responsibilities similar
Agencies Use a Variety of   to FPS also used a variety of methods to collaborate with state and local
Methods to Collaborate      law enforcement. For example, VA has a policy requiring all locations of
                            VA-controlled property to have formally documented MOUs with state and
with State and Local Law    local law enforcement agencies to ensure timely backup support for VA
Enforcement                 Police officers. 19 VA headquarters officials stated that MOUs are useful
                            because VA Police typically transport detainees to state and local law
                            enforcement agencies for arrest and processing, while state and local law



                            19
                              Department of Veterans Affairs: Security and Law Enforcement VA Handbook 0730
                            (Washington, D.C.: Aug. 11, 2000).




                            Page 12                                     GAO-12-434 Law Enforcement Collaboration
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 20 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.

According to a Smithsonian Institution headquarters official, the
Smithsonian police rely on MPD and the Park Police to arrest and
process suspects in the District of Columbia. Aside from a limited MOU
with the District of Columbia, MPD 21 the Smithsonian police does not
have MOUs with other law enforcement agencies. In the District of
Columbia region as well as nationally, Smithsonian police rely on informal
relationships with state and local law enforcement agencies for
coordination of law enforcement at Smithsonian-controlled property.
However, Smithsonian police officials stated they cannot provide mutual
aid— due to lack of authority—to state and local law enforcement
agencies on non-Smithsonian-controlled property.




20
 38 U. S. C. § 902.
21
  The MOU assists the Metropolitan Police Department. D.C. to conduct crime prevention
and law enforcement activities for specific instances or periods of time specified by the
Smithsonian Institution’s Office of Protective Services. The MOU allows officers from the
National Zoo in Washington, D.C. to direct traffic in the immediate surroundings of the Zoo
or in the instances of hot pursuit for example, to take action from outside the perimeter of
the Zoo if appropriate to protect the Zoo’s property, visitors, and animals.




Page 13                                         GAO-12-434 Law Enforcement Collaboration
State and Local Law                          Our questionnaire of state and local law enforcement agencies and
Enforcement Generally                        follow-up discussions showed a general willingness of those that replied
Willing to Assist with                       to respond to incidents at federal facilities. For example, 48 of 52
                                             agencies that answered the question replied that they would respond to
Protecting Federal                           calls that dispatch to a federally occupied (owned and/or leased) building,
Facilities                                   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.

Table 1: State and Local Law Enforcement Agencies’ Responses to Selected Questions in GAO’s Structured Questionnaire
Regarding FPS Collaboration

                                                                                                                  Answers
                                                                                                                              No
            a
Questions                                                                                                        Yes    No answer
                                                                               b
To your knowledge, are there federal buildings located within your jurisdiction?                                   55    1         1
Would your law enforcement entity respond to calls that dispatches to a federally occupied (owned
and/or leased) building?                                                                                           48    4         5
Since 2007, has your law enforcement entity been denied access into federally occupied (owned
and/or leased) building in response to an incident under your entity’s purview (proprietary of the
state or local government, or concurrent with the federal government)?                                              1   38       18
Since 2007, has your law enforcement entity responded to a call that dispatches to a federally
occupied (owned and/or leased) building?                                                                           27   17       13




                                             Page 14                                         GAO-12-434 Law Enforcement Collaboration
                                                                                                                                      Answers
                                                                                                                                                  No
            a
Questions                                                                                                                            Yes    No answer
Since 2007, has your law enforcement entity declined to respond to a call that dispatches to a
federally occupied (owned and/or leased) building?                                                                                      1   43       13
Since 2007, does your law enforcement entity have any formal memorandums of understanding
(MOUs) with the U.S. Department of Homeland Security, Federal Protective Service?                                                      11   32       14
Does your law enforcement entity have any informal agreements with the U.S. Department of
Homeland Security, Federal Protective Service?                                                                                          4   36       17
                                            Source: GAO structured questionnaire of state and local law enforcement agencies.

                                            a
                                             Not every respondent answered every question.

                                            b
                                             Although we selected our respondents based on addresses of federal buildings located in their
                                            probable geographic jurisdictions, upon further examination, one respondent noted that a building
                                            address we chose was actually one street out of its jurisdiction. Therefore it answered that it had no
                                            federal buildings in its area of jurisdiction.



FPS’s Approach Is                           Overall, the variety of efforts FPS has under way reflects a reasonable
Reasonable and Consistent                   approach to collaboration, especially when combined with results we
with Key Practices                          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                 Although FPS’s approach to collaboration is reasonable, issues related to
Are of Concern, and Data                    data quality arose during our review. Specifically, we found that FPS
Inconsistencies with GSA                    lacked complete data from GSA on the type of jurisdiction (e.g.,
                                            concurrent or exclusive) for about one-third of the buildings FPS protects,
Are Being Addressed                         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,


                                            Page 15                                                              GAO-12-434 Law Enforcement Collaboration
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.)

Table 2: Jurisdiction of Properties under the Control of GSA with FPS
Responsibility
                   a,b
    Jurisdiction                      Number of GSA Properties                            Percentage
    Pending                                                       1594                                18
    Exclusive                                                       329                                4
    Concurrent                                                      662                                7
    Partial                                                          31                                0
    Proprietary                                                   4969                                55
    Combined                                                         21                                0
            b
    Blank                                                         1432                                16
    Total                                                         9038                              100
Source: GAO analysis of GSA data.

a
 GSA provides the following guidance when assigning jurisdiction to its properties: Pending: requires
value assignment in the database; Exclusive: the U.S. enjoys exclusive legislative jurisdiction and the
state has no legislative jurisdiction except for minor forms of taxation; Concurrent: both the U.S. and a
state enjoy complete legislative jurisdiction; Partial: the state has selectively ceded certain aspects of
legislative jurisdiction to the U.S; Proprietary: the state exercises complete legislative jurisdiction and
the U.S. is considered only a property holder; Combined: any location at which more than one of the
above jurisdictions exist.
b
Blank represents number of facilities missing GSA jurisdictional data.

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.




Page 16                                                 GAO-12-434 Law Enforcement Collaboration
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




Page 17                                  GAO-12-434 Law Enforcement Collaboration
completed if FPS is unaware of the new lease. 22 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. 23 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.



22
  The current MOU between FPS and GSA began on June 1, 2006, and was valid for 2
years. However, the MOU states that upon expiration of the initial term, the MOU will
automatically be renewed and will remain in full force and effect until modified in writing,
executed by both parties, or terminated by either party upon 90 days’ written notice to the
other party.
23
  Each federal building is assessed a security risk level, with Level 1 as lowest and Level
5 as highest. FPS uses Interagency Security Committee guidelines to determine a
facility’s security level, which in turn determines the level of physical protection services
needed at each of the approximately 9,000 buildings.




Page 18                                          GAO-12-434 Law Enforcement Collaboration
                      FPS’s approach to collaborating with state and local law enforcement is
Conclusions           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.


                      In conjunction with the revised MOU that is being developed between
Recommendations for   GSA and FPS, we recommend the Administrator of GSA ensure that
Executive Action      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.


                      We provided a draft of this report to GSA, DHS, DOI, VA, and
Agency Comments       Smithsonian Institution for their review and comment. GSA provided
and Our Evaluation    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


                      Page 19                                 GAO-12-434 Law Enforcement Collaboration
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.

Sincerely yours,




Mark Goldstein
Director
Physical Infrastructure Issues




Page 20                                  GAO-12-434 Law Enforcement Collaboration
Appendix I: Objective, Scope and
              Appendix I: Objective, Scope and Methodology




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. 1 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




              1
               GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1.
              (Washington, D.C.: November 1999); GAO, Homeland Security: Further Actions Needed
              to Coordinate Federal Agencies’ Facility Protection Efforts and Promote Key Practices,
              GAO-05-49 (Washington, D.C.: Nov. 30, 2004); GAO, Results-Oriented Government:
              Practices That Can Help Enhance and Sustain Collaboration among Federal Agencies,
              GAO-06-15 (Washington, D.C.: Oct. 21, 2005).




              Page 21                                        GAO-12-434 Law Enforcement Collaboration
Appendix I: Objective, Scope and Methodology




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. 2

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


2
 Results from nonprobablity samples cannot be used to make inferences about a
population because in a nonprobability sample, some elements of the population being
studied have no chance or an unknown chance of being selected as part of the sample.




Page 22                                        GAO-12-434 Law Enforcement Collaboration
Appendix I: Objective, Scope and Methodology




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.




Page 23                                        GAO-12-434 Law Enforcement Collaboration
Appendix II: Comments from the General
              Appendix II: Comments from the General
              Services Administration



Services Administration




              Page 24                                  GAO-12-434 Law Enforcement Collaboration
Appendix III: Comments from Department of
             Appendix III: Comments from Department of
             Homeland Security



Homeland Security




             Page 25                                     GAO-12-434 Law Enforcement Collaboration
Appendix III: Comments from Department of
Homeland Security




Page 26                                     GAO-12-434 Law Enforcement Collaboration
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Mark Goldstein, (202) 512-2834 or goldsteinm@gao.gov
GAO Contact
                  In addition to the contact named above, David Sausville (Assistant
Staff             Director), Maren McAvoy, and George Depaoli made key contributions to
Acknowledgments   this report. Additionally, Colin Fallon, Kathleen Gilhooly, Hannah Laufe,
                  and Andrew Stavisky aided in this assignment.




(543282)
                  Page 27                               GAO-12-434 Law Enforcement Collaboration
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