Real Estate Industry Comments on EPA Guidance, March 2002

NYC 9/11 Public Portal Document

Ms. Elissa Feldman March 25, 2002 Page 6

e.) Identification System: According to a major property management company, the recommendation to introduce an identification system to limit access to properties and check all packages prior to entry is unrealistic in many properties because of multiple entrances. The company notes that in larger properties, the costs to implement the system will introduce an undue financial burden. It is also pointed out that many older high-rise properties do not have sufficient lobby space to facilitate screening installations f.) Filtration: According to the same property management company, the entire discussion regarding filtration is flawed. The point is made that while many of the principles set out in that section are accurate; their application is misguided, confusing or so non-specific as to be meaningless. The comment states, by way of example, that “the first section discussing HVAC Controls offers sequentially, contradictory recommendations each time stating, ‘...in some cases do this,’ without discussing what those conditions are. Even with the additional information, one must ask whether the individuals charged to operate a building are capable of correctly assessing and reacting to this kind of situation.”

g.) Return Air Grill Relocation: According to one comment the apparent recommendations to relocate return air grills and convert open design return air plenums to a ducted design are ill conceived, poorly reasoned and unjustified. h.) Negative Pressure Requirement: One comment relates to Section B. Physical Security, Subsection 5, “Isolation of Lobbies, Mail Rooms, loading docks.... ” The section discusses maintaining a negative pressure in these areas. According to the commenter, , negative pressure in a building lobby presents a host issues, starting with pulling in dust and debris from the street to infiltration of external contaminants (i.e. pollution and possibly environmental/biological contaminants). The commenter agrees that the HVAC systems in these higher risk areas should be isolated from the rest of building but points out they should operate as customarily designed. Conclusion In conclusion, the real estate industry welcomes the opportunity to work with you, the Office of Homeland Security and the other federal agencies that make up the Workgroup to limit the risk of — and harm caused by — bio-terrorist attacks on commercial and multi-family buildings. I have no doubt that the Workgroup’s final work product will reach a broad audience and will add to the quality of national dialogue on building security. I hope you will read and consider these comments in the constructive spirit in which they were offered and will revise the current draft to meet our concerns. The more flexible and practical federal guidelines can be in this area the more likely they are to receive serious attention among all sectors of our industry. At the Roundtable, and at affiliated trade associations, we will certainly do our best to make the Workgroup’s important initiative a success. Of course, as you proceed with more detailed guidance, we stand ready to offer a private sector perspective on those projects as well.

Sincerelv.

Roger Platt Senior Vice President and Counsel

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