REQUEST FOR RELIEF FROM GSA REGULATIONS FOR JUSTIFYING WORD PROCESSING EQUIPMENT ACQUISITIONS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84-00933R000400030010-6
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 14
• Document Creation Date: December 19, 2016
• Document Release Date: October 27, 2006
• Sequence Number: 10
• Publication Date: April 20, 1981
• Content Type: REGULATION

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low
20 April 1981
REQUEST FOR RELIEF FROM GSA REGULATIONS FOR JUSTIFYING
WORD PROCESSING EQUIPMENT ACQUISITIONS
Advancing technology in the word processing equipment (WPE)
field has increasingly blurred the distinction between WPE and
automatic data processing equipment (ADPE). In a February 1980
GSA Bulletin (Federal Property Management Regulation (FPMR)
A-75), GSA recognized this and reclassified WPE as ADPE for
management purposes. However, GSA saw fit to require that
determination of need for WPE (i.e., justification) be governed
by the rules set forth in the Archives and Records subchapter of
the FPMR's (FPMR 101-11.9). These rules promulgated by the
National Archives and Records Services Administration (NARS)
require that WPE be justified as a typewriter replacement on the
basis of savings in typing time. Our view is that this approach
is technologically out-of-date and does not recognize that WPE
ideally is used as part of an integrated office automation
network. An office automation network offers capabilities such
as electronic mail, automated registries, access to printing and
publishing facilities, electronic filing, etc. Use of WPE is, in
fact, a method for capturing keystrokes, which is the first step
in automated information resources management. The current NARS
procedures take a much narrower, frankly old-fashioned view.
Currently four (4) ODP personnel are required to perform the NARS
justification studies. If WPE were treated as ADPE, without
regard for the NARS procedures, these resources could be largely
redirected to office automation studies. WPE would then be
justified on the basis of the overall benefits to be derived from
attaching an additional workstation to the office automation
network and not exclusively for its value as a typewriter
replacement. Thus, if relief from the NARS procedures were
obtained for CIA, a more realistic justification procedure could
be used for WPE as well as significant personnel savings
achieved.
Request
That the Administrator of GSA grant CIA authority to treat
WPE as falling exclusively within the existing CIA delegation of
procurement authority for ADP. Specifically, the CIA be relieved
from following NARS justification procedures (FPMR 101-].1.9) for
acquiring WPE and be permitted to follow the ADP procedures
outlined in FPMR 101-35.
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CDPF--81-265
3 MAR 1981
)' DLW POs Deputy Director for Administration
!'F t *rrace 3`. Johnson
Director of Data Processing
SUBJECT s Waiver of M. regulations Governing
Word cesa,ing Lqui nt
1, Attached is a staff study, coordinated with the Office
of Logistics, vbich addresses the problem created for us because
GSA requlatier?s fail to treat word processing equipment (t+PE) aa.g
an Integral mart of ADP and particularly off ice autoration
sytte ts. Because of the relationship of N'PF procure pent with the
tocurement of otter ADPF under our delecation of, yrocure*.cnt
authority (c?A) I bave provided soap information about the DVA
ant cur success in ewplcyinq it. I believe It will give ycr that
you need to prepare for diecusslen of t?hie subject with the now
'drinisatraatcr of the GSA.
2. The staff study is longer than I had doped, but the
subject is a technical one and difficult to su arise. Since
votrr time is limited you flay iisb to concentrate on the sections
I [wave his lights 1, Sections I (Problex), III (Liscussai:t n,
J=-arssgrephs E, F and C), IV (Conclusions ), and V
(Pecosroendations ).
3. You nay have concluded from our introductory discuaasior
of [PDP that Z 'felt we had some fundamental problems with AVPP
procure nt in general. My intention was to acquaint you wit3:
the ways is wbich the procurement process impinges on our
cperwtion, and indeed we are forced to Invest considerable effort
in support of procurement. As the staff study sLa, however, I
consider the req iresent for coral etitive procure ent to he
reaeonet,le and I believe our delegation of procureutent authority
from GSA serves our i..urposea extremely well. It is only in the
area of word processing where some changes are needed.
4. Preparation of a formal request for waiver (or
'deviation,' as It is called) to per it CIA to proceed with its
word ireces&ing/office automation prorrar unhindered by GSA
regulations will require addd#tio: a2 time. The staff- st:uly was
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tts first steii, outlinir q the basis for the; cast to to made to
GSA in rakiaq the quest. Unless instructed otherwise as s
result of your discussions at Okk, I will collaborate with
OL/ curasent and - the Office .Central Counsel is the
Preparatjoe of the forsal t queat*
Is/ Bruce T. Johnson
?race T. Johnson
Attachments a
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WORD PROCESSING AS AN INTEGRAL PART OF AN
OFFICE AUTOMATION PROGRAM
l4~.,, J98
r
to be justified 'only when
s can be cited.
with its emphasis on
information management instead of records management I
Ind valuable manpower that could be addressing the
challenges and opportunities of office automation must be invested
instead in volumetric studies of the ways in which word pro-
cessors are to be used in offices requesting installations.
II. Facts Bearing on the Problem:
A. In April 1979 GSA, citing technological advancement which
made it "increasingly difficult to differentiate between WPE
processing equipment] and ADPE," redefined all WPE as ADPE andword
subjected WPE to the procurement regulations which implement the
Brooks Act.
B. The redefinition of WPE did not remove it from the purview
of NARS, and regulations governing its acquisition and use remain
in the Records Management (FPMR 101-11) section of the FPMR's, just
after Vital Records and Forms and preceding Reports Management and
Aidiovisual Records.
C. Acquisition of automatic data processing equipment
(ADPE) for the Federal Government is governed by the Brooks Act., PL
89-306, 40 U.S.C. 759. The Act authorizes and directs the
Administrator of the GSA "to coordinate and provide for the
ecomonic and efficient purchase, lease and maintenance of automatic
data processing equipment by Federal agencies." it permits him
to delegate authority to other federal agencies to acquire and
operate ADPE when "necessary for the economy and efficiency of
operation, or when such action is essential to national defense or
national security." it stipulates, however, that the Administrator
is not to "interfere with, or attempt to control in any way," the
use made of ADPE. The Act also gives the Secretary of Commerce
certain authorities regarding the establishment of uniform Federal
ADP standards. The language of the Brooks Act gives it. preeminence
over other inconsistent provisions of law, so CIA cannot employ the
extraordinary authorities of the DCI to avoid application of GSA's
implementing regulations, except insofar as the Administrator
grants a waiver.
D. In December 1973 GSA issued to CIA a delegation of
Procurement authority (DPA) for "the lease, purchase and/or
maintenance of ADPE and related items." The DPA prescribed,
however, that the Agency must follow all applicable procurement
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regulations and it cited a number of specific Federal Property
Management Regulations (FPMR's) which were to be followed. It also
provided for an annual review of procurement actions. ,In an
amendment dated 29 September 1978 GSA added ADP services to the DPA
and updated the references to various applicable regulations.
The DPA carries the stipulation that it can be voided for "failure
to operate within the established limitations."
E. GSA's regulations, supplemented by instructions and
circulars from OMB (e.g. Circular A-71 on Responsibilities
for the Administration and Management of ADP Activities), establish
comprehensive rules governing the acquisition of ADPE. Prime among
the requirements is the need to demonstrate a maximum reliance on
competition to ensure the advantages of lower costs and to give as
many vendors as possible access to the Federal market.. In their
broad interpretation of the Brook`s Act GSA has had the consistent
and active support of Congressman 'Brooks, who has made himself the
watchdog of ADPE procurement and use in the. Federal establishment.
F. CIA and the Intelligence Community have supported the
concept of competitive procurement. In NFIB 74.2/25, 8 November
1977 on NFIP Procurement Policy, the then DCI stated that "all
procurement, whether by formal advertising, or by negotiation,
within the limitations of statutory responsibilities to protect
sensitive intelligence sources and methods, should be made on a
competitive basis to the maximum practical extent." In
31 May 1978, on CIA Procurement Policy, the then DDCI reiterated
this NFIP policy and stressed the need for thorough justification
wherever sole-source procurement is proposed.
G. In December 1980 the so-called Paperwork Reduction Act of
1980 (P.L. 95-511) was passed. Among its purposes was "to ensure
that automatic data processing and telecommunications technologies
are acquired and used by the Federal Government in a manner which
improves service delivery and program management, increases produc-
tivity, reduces waste and...the information processing burden..."
Because the Act would give additional oversight authorities to the
Director of OMB, ADPE and telecommunications equipment used for
military or intelligence activities were excluded. During
legislative debate on the bill, however, Senator Jackson found the
opportunity to assert that "to the maximum degree feasible...
competitively bid procedures would continue to be employed in the
acquisition of...ADP equipment used in support roles for military
and intelligence activities," and Congressman Brooks, in accepting
the proposed exclusion amendment, asserted that "existing statutes
[e.g. the Brooks Act] covering these activities are not affected by
this amendment." Thus the Paperwork Reduction Act became at once a
form of reinforcement for the application of GSA regulations to
CIA's ADPE procurement, and a source of new guidance regarding the
ways in which WPE, as a subset of ADPE, could be used "to improve
the effectiveness of the use and dissemination of data in the
operation of Federal programs..."
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H. In the CIA report of October 1980 to the National Academy
of Public Administration (NAPA) in support of NAPA's in-depth
review of GSA, the Agency used the delegation of ADPE,procurement
authority as the model for the kind of shift in responsibilities
needed if other services essential to CIA were to be at all
adequate.
A. Word processing aside, the procurement of ADPE under the
Agency's DPA is working extremely well. At a time when critics of
GSA (such as the General Accounting Office and the Federal Data
Processing Reorganization Study) are pointing out that it can (and
usually does) take from 2 to 6 years to procure new computer
systems through GSA, CIA is issuing Requests for Proposal (RFP"s)
and bringing in CPU's, other peripheral hardware, and various ADP
services in a fashion that is the envy of other Federal ADP
managers who come to us for advice. Our last CPU, for example,
took 74 days from issuance of RFP to award. The current pro-
curement of our 3033 MP, interrupted by the equipment moratorium,
could have been completed in 102 days (71 from the date of the last
RFP amendment). ODP and OL/Procurement work closely and in harmony
to obtain the equipment and services needed to keep CIA's data
processing establishment equipped with the latest technology. Our
management of these processes under the DPA is audited periodically
but not disruptively by GSA, which has consistently found our
procedures to be legal and proper. Given continuing Congressional
concern over maintenance of a competitive approach to ADPE
procurement, such audit reports represent an excellent defense
against any charges by critics of CIA that we high-handedly ignore
the FPMR's and the will of Congress. In a time of strong sentiment
for checks and balances on Federal authority, the relationship
represented by our DPA can be perceived as clearly advantageous to
CIA.
Nor does the subordination of the ADPE procurement process to
another agency's delegation inhibit our ability to protect sen-
sitive sources and methods information. We have been supported in
our insistence that the routine publicity attending most Federal
procurement cannot be provided, and the language of the DPA, which
says that the limitations imposed must be followed "within the
bounds of security," has provided the necessary latitude for our
procurement officers to adapt their procedures to meet the needs of
security.
One additional factor should be cited. Competition has not
infrequently brought real savings. Care must be taken to ensure
that we do not take on long-term, hidden systems maintenance costs
when we accept a "bargain" proposal, but as we have grown more
sophisticated in our use of this procurement tool, we have been
able to avoid most such pitfalls. For a combination of security
and system stability reasons we have insisted on limiting the
number of vendors with whom we deal, and OL/Procurement has
supported us in this regard.
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B. Turning to word processing, it is possible to see how the
requirement to follow GSA regulations can become burdensome when
those regulations are out of step with the technological facts of
life. - - - - ' I - ban, ,.~...~....__ A
py;A The regulations push
us constantly toward competition and require careful documentation
when security or technical reasons call for sole source
procurement, but the GSA review does not speak to the ways in which
we use ADP. As noted above, the Brooks Act prohibits such
or-r. XG,SA- rZvi i tut rr, A -D S- 4
-
;i Little consideration has been given to the
emerging technological merger of these two fields.
QaawwL at a
time when the technologies underlying the ADP, telecommunciations
and office and records management are becoming virtually
indistinguishable parts of common information system technology,
pp.r aaAc ti . "
C. The NARS approach to WPE is illustrated dramatically in
the January 1979 GSA Bulletin FPMR B-86 on "Use of word processing
equipment," which used a cost comparison of WPE with electric
typewriters as a basis for imposing cost-effectiveness determinants
for the justification of acquisitions of WPE. No reference is made
to the increasing concern for the effective capture of keystrokes
as an essential first step in the automation of office functions.
In the February 1980 Bulletin (FPMR A-75) which enunciated the
reclassification of WPE as ADPE, GSA saw fit to require that the
determination of need for WPE was to be governed by the rules set
forth in the Archives and Records subchapter of the FPMR's. Those
rules speak of ensuring "that an objective need for increased
efficiency and effectiveness has been established and that all
reasonable alternatives...have been considered," among those
alternatives being typing training, work simplification and
increased use of dictation equipment (FPMR 101-11.9).
D. GSA Bulletin FPMR A-75 announced the formation of a GSA
task force to review "necessary FPMR revisions regarding the
application of WPE to office automation consistent with management
and acquisition provisions for ADPE...as an information technology
resource." The target date for issuance was 31 December 1980, but
we have not seen any results.-
E. The approach taken by the vendors of WPE has, until
recently, encouraged narrow views of the significance of this
technology. Emphasis has been on the secretary's efficient
manipulation of textual material; systems integration has only
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recently become a significant part of the sales pitches as new
F. I
ne o the most popular forms o word
processing has been and continues to be the SCRIPT facility under
our interactive VM system. We have built text processing
capabilities into our new standard terminal and plan at-software
package for the terminal to provide basic word processing
capability. As newer generation VDU word processors have come into
use we have collaborated with NFAC to create effective links
between their interim standard (NBI) word processor installations
and ODP's computers, and thence to OL's Electronic Text Editing and
Compositing System (ETECS).
H. The Paperwork Reduction Act requires each agency to
designate a senior official to oversee its major information
systems and ensure their effective coordination. (As noted, CIA's
ADPE was excluded from the Act, but OGC is currently reviewing the
other provisions to determine how they affect CIA.) With
establishment of the position of Information Systems Architect, CIA
has already begun to address the coordination problem which was one
of the Act's targets. The development of SAFE, while not the only
sign by any means, is perhaps the most dramatic piece of evidence
that CIA has attempted to do one of the things the Act calls for,
that is, promote the use of ADP to improve effectiveness in the use
of data. Now that we have in place an official whose task it is to
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 ILLEGIB
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ensure information systems compatibility, we would seem to be in an
excellent position to urge GSA to take the redefinition of WPE the
final logical step, to let it be treated as an integral part of
larger ADP-based information systems.
I. The Federal Procurement Regulations (FPR's) provide for
what are termed "deviations," which may be authorized by the GSA
Administrator or his designee. Requests must be in writing and
must describe the nature of the deviation and the reasons for it.
The restrictions under
is we operate are those laid down in principle by Congress, and
although not without burden, keep our procurement program in line
with prevailing convictions about what is "right" for the country's
economy.
B. The management of word processing equipment is inap-
propriately divorced from the rest of ADPE by GSA and the FPMR's,
thus inhibiting efforts to move systematically in the direction of
greater automation in our information handling systems.
C. CIA has the structure, the expertise and the organiza--
tional discipline to develop effective office automation programs.
D. General relief from the limitations on procurement of WPE
(FPMR 101-11.9) for those agencies with effective controls over the A
growth of ADP systems would release resources for development of
forward-looking information management systems. If general relief
is not feasible at this time, a specific waiver for CIA would
permit us to get on with the task.
ILLEGIB
A. That the DDA call the problem of word processing
management as described above to the attention of the newly-
appointed Administrator of GSA;
B. That the Administrator be urged to reposition WPE manage-
ILLEGIB ment under FPMR 101-35; and,
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LETTERHEAD
The Central Intelligence Agency is constantly seeking and
testing new technology as one means of more effectively
performing its mission. One objective is to employ our automatic
data processing (ADP) capability to streamline our information
handling process, to reduce the time required to exchange
information particularly between A
The Honorable Gerald P. Carmen
Administrator
General Services Administration
18th and F Street, N. W.
Washington, D. C. 20405
Dear Gerry:
~-.I-cy ents that are
widely dispersed; and to use our ra
lcomponcomputifacilities as
part of our movement towards our office of the future. This is
to permit us, for example, to link electronic mail, registry
systems, budgeting systems, inbound and outbound cable
dissemination, and publications preparation to our central
computer systems and use our computers to store, collect,
process, and distribute information. (S)
We use the processes outlined in Federal Procurement
Regulation (FPR) 1-4.11 and Federal Property Management
Regulation (FPMR) 101-35.2 for the procurement and management-of
automatic data processing equipment (ADPE). During the time
frame that the notion of word processing (WP) and word processing
equipment. (WPE) was becoming popular, we installed a capability
on our large, time-sharing computers that would permit, using
remote terminals, the development, modification, electronic
distribution, and printing of documents such as handbooks,
memoranda, etc. For example, in 1977 we procured in conformance
with the procedures established in Public Law 89-306 (Brooks Act)
a standard terminal for Agency-wide use. This procurement action
was in accordance with Government wide procedures for ADPE
acquisitions and included a requirement, among others, for a word
processing capability for a class of "smart" terminals. (S)
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Thus, we have been moving in the direction of word
processing for some time. Because of the adventiof WPE with the'-
capability to communicate with our central computing facilty, we
wish to treat WPE as we would treat any other. piece of ADPE. . For
example,_.we wish to establish a standard?'for.WPE that-includes a
family-,of -equipment that is upward compatible and able to
communicate with our computers. As a matter of fact,- this Agency=-F--
has arrived at-a point where WPE is increasingly used as a data
. entry device to our ADP services, rather than just a typewriter,
and where in our mind WPE is another type of ADPE. (S)
At present, we are devoting the services of four highly
trained systems analysts to determine and document the need for
WPE as prescribed by FPMRThese analysts' services are
sorely needed and could be better utilized in our program of
seeking, testing, and implementing new technology to assist in
the performance of our mission. For example, we wish to move our
precious technical talent from the marginal activity of
justifying WPE (the data entry device) to the real problem of
electronic records control. It seems that we are entering a
revolutionary period in information management and should be
looking at such questions as how to control information in the
"paperless world" before it gets lost in the "electronic; ..
information sea", or how to relate information in the "paper
world" to the "paperless world", or what is the future role of
Records Management Officers? We find that justifying WPE on the
basis of cost effectiveness as required by FPMR 101-11.9 and
determining the cost effectiveness in acquiring WPE as required
by GSA Bulletins FPMR B-86, 17 January 1979, and FPMR A-75,
14 February 1980, is not cost effective in itself and consumes
manpower that could be more productively used elsewhere. (S)
I ask for a deviation for the Central Intelligence Agency to
use the processes outlined in FPR 1-4.11 and FPMR 101-35.2 for
the procurement and management of word processing equipment
without regard to FPMR 101-11.9. Trusting that you agree, I have
attached a letter for your signature that grants a deviation to
the Central Intelligence Agency. (U)
Sincerely,
Max Hugel
Deputy Director
for
Administration
Attachment: a/s
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The Honorable William J. Casey
Director of Central Intelligence
Washington, DC 20505
Dear Mr. Casey:
Based on the justification appearing in Mr. Hugel"s letter
of , 1981, please be advised that Federal Property
Management Regulation 101-11.9 shall have no application to word
processing equipment included within the definition of automatic
data processing equipment provided for in FPMR 101-35.202-1, and
meeting the requirements of the Central Intelligence Agency.
This deviation for the Central Intelligence Agency is
authorized on the basis that all Federal Procurement Regulations
and Federal Property Management Regulations applicable to
procurement and management of automatic data processing
equipment, Federal Procurement Regulation 1-4.11, and Federal
Property Management Regulation 101.35 shall be followed for word
processing equipment.
Sincerely,
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