NYC 9/11 Public Portal Document
P 5) The Real Estate Roundtable
March 25, 2002
Ms. Elissa Feldman
Associate Director
Indoor Environments Division
Office of Air and Radiation
U.S. Environmental Protection Agency
Mail Code (6609J)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: Draft Guidance for Protecting Building Environments from
Airborne Chemical, Biological or Radiological Attacks
Dear Elissa:
This letter summarizes a variety of real estate industry comments on the draft “Guidance for
Protecting Building Environments from Airborne Chemical, Biological or Radiological Attacks.” (the
“Guidance”). We understand the Guidance was developed by the Workgroup on Building Air
Protection (Workgroup) working under the auspices of the President’s Office on Homeland Security
(OHS). As an industry, we strongly support the efforts of the President to fully engage the real estate
sector — on a voluntary basis — in the Nation’s homeland security efforts. With many tenants
demanding unprecedented attention to security issues, we believe the industry is highly motivated to
consider any and all reasonable and constructive guidance in this area.
The comments set out below represent the views of security and engineering experts at various
companies participating in The Real Estate Roundtable RER), as well as those of members of the
Building Owners and Managers Association, International (BOMA); the Institute of Real Estate
Management (IREM); the International Council of Shopping Centers (ICSC), which includes retail
tenants; the National Association of Real Estate Investment Trusts (NAREIT); the National Association
of Realtors (NAR); and, the Real Estate Board of New York (REBNY). The respective mission
statements of those seven organizations are attached. In addition, a joint comment letter from IREM and
NAR is also attached. While affiliated with the Roundtable, we understand that the National Multi
Housing Council/National Apartment Association is providing comments in separate and independent
communications.
Summary
The comments described below reflect the concerns of diverse segments of the national real
estate market including the owners of large “trophy” properties in and around central business districts
and owners of small office, retail, and residential buildings in outer suburban and rural areas. While
owners of smaller properties were often more wary of the scope of the Guidance than others, most
responses were marked by respect for the constructive tone and substance of the Workgroup’s initial
recommendations. When serious concerns were raised they tended to focus on specific suggestions that
were seen as having limited applicability and/or cost-effectiveness when applied to certain types of
existing buildings. Even for the authors of some of those comments, however, the fact that the
document was guidance — and not a set of inflexible mandates — went some distance toward
alleviating those concerns.
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