ATF: Thefts of Explosives from State and Local Government Storage
Facilities Are Few but May Be Underreported (31-OCT-05,
GAO-06-182T).
More than 5.5 billion pounds of explosives are used each year in
the United States by private sector companies and government
entities. The Bureau of Alcohol, Tobacco, Firearms and Explosives
(ATF) has authority to regulate explosives and to license
privately owned explosives storage facilities. After the July
2004 theft of several hundred pounds of explosives from a local
government storage facility, concerns arose about vulnerability
to theft. This testimony provides information about (1) the
extent of explosives thefts from state and local government
facilities, (2) ATF's authority to regulate and oversee state and
local government storage facilities, and (3) security measures in
place at selected state and local government storage facilities.
This information is based on a report GAO is releasing today on
these issues.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-06-182T
ACCNO: A40637
TITLE: ATF: Thefts of Explosives from State and Local Government
Storage Facilities Are Few but May Be Underreported
DATE: 10/31/2005
SUBJECT: Explosives
Facility security
Federal regulations
Government facilities
Larceny
Law enforcement
Safety regulation
Safety standards
Security assessments
Regulatory agencies
Intergovernmental relations
Warehouse facilities
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GAO-06-182T
United States Government Accountability Office
GAO Testimony Before the Subcommittee on National Security, Emerging
Threats, and International Relations, Committee on Government Reform,
House of Representatives
For Release on Delivery
Expected at 9:00 a.m. PST ATF
Monday, October 31, 2005
Thefts of Explosives from State and Local Government Storage Facilities Are Few
but May Be Underreported
Statement of Laurie E. Ekstrand Director, Homeland Security and Justice
GAO-06-182T
[IMG]
October 2005
ATF
Thefts of Explosives from State and Local Government Storage Facilities Are Few
but May Be Underreported
What GAO Found
Judging from available ATF data, there have been few thefts of explosives
from state and local government storage facilities. From January 2002 to
February 2005, ATF received 9 reports of thefts or missing explosives from
state and local facilities, compared with a total of 205 explosives thefts
reported from all sources nationwide during this same period. During the
course of the audit, GAO found evidence of 5 thefts from state and local
government facilities, 1 of which did not appear in ATF's national
database of thefts and missing explosives. Thus, the actual number of
thefts occurring at state and local facilities could be higher than that
identified by ATF data.
ATF has no authority to oversee or inspect state and local government
explosives storage facilities. State and local agencies are not required
to obtain a license from ATF to use and store explosives, and only
licensees- such as private sector explosives storage facilities-are
subject to mandatory oversight. Thus, ATF has no means to ensure that
state and local facilities comply with federal regulations. Further, ATF
does not collect nationwide information on the number and location of
state and local storage facilities, nor does the agency know the types and
amounts of explosives being stored in these facilities. Because this data
collection is a function of the licensing process and state and local
facilities are not required to be licensed, no systematic information
about these facilities is collected. By comparison, all licensed private
sector facilities must submit a variety of information about their
facilities-including location and security measures in place-to ATF during
the licensing process. ATF also collects information about these
facilities during mandatory inspections.
At the 18 state and local government storage facilities GAO visited, a
variety of security measures were in place, including locked gates,
fencing, patrols, and in some cases electronic surveillance. All the
facilities' officials told GAO that they conducted routine inventories.
But most of the state and local government entities GAO visited were not
required to be licensed or inspected by state or local regulatory
agencies. GAO identified several instances of possible noncompliance with
federal regulations, but these were related primarily to storage safety
issues rather than security.
Explosives Storage Facilities in Pennsylvania and Texas
Source: GAO.
United States Government Accountability Office
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today to discuss security and safety at state and
local government explosives storage facilities. More than 5.5 billion
pounds of explosives are used each year in the United States. These
explosives are used by both public sector entities (such as state and
local government agencies) and private sector companies for a variety of
purposes-including mining, construction, avalanche control, and law
enforcement. Under current federal explosives laws and regulations, the
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is responsible
for licensing and regulating explosives manufacturers, importers, dealers,
and users. It is primarily through this licensing authority that ATF
oversees and inspects privately owned explosives facilities to ensure they
comply with federal explosives storage laws and regulations. However,
state and local government agencies are exempt from ATF licensing
requirements.
In August 2004, the subcommittee held a hearing here in California to
investigate the July 2004 theft of several hundred pounds of explosives
from a storage facility being used by local law enforcement agencies. At
that hearing, the subcommittee heard testimony from federal, state, and
local officials regarding the safety and security of publicly managed
explosives storage facilities and the adequacy of federal authority to
regulate and oversee these facilities. Out of concern that state and local
government explosives storage facilities could be vulnerable to theft, you
asked us to study the security and oversight at these facilities.
My testimony this morning is based on a GAO report1 being released today
in conjunction with this hearing, and will focus on the following issues:
1. the extent to which state and local government explosives storage
facilities have been vulnerable to theft,
2. the extent to which ATF regulates and oversees state and local
government explosives storage facilities, and
3. the types of security measures in place at selected state and local
government explosives storage facilities.
1GAO, ATF: Thefts of Explosives from State and Local Government Storage
Facilities Are Few but May Be Underreported, GAO-06-92 (Washington, D.C.:
Oct. 3, 2005).
Summary
We conducted our work on this report from February 2005 to August 2005 in
accordance with generally accepted government auditing standards.
Judging from available ATF data, there have been few thefts reported at
state and local government explosives storage facilities. However, these
reported thefts could be understated by an unknown amount. During the
3-year period from January 2002 to February 2005, ATF received 9 reports
of thefts or missing explosives from state and local law enforcement
storage facilities, compared with 205 thefts from all sources nationwide.
Similarly, during a 10-month period (ending December 2003), there were 76
theft incidents reported nationwide resulting in a loss of about 6,700
pounds of high explosives and blasting agents. By comparison, over an
entire 10-year period (ending December 2004), ATF received 14 reports of
theft from state and local law enforcement storage magazines, resulting in
reported losses of about 1,000 pounds of explosive materials. The actual
number of state and local thefts could be higher than indicated by ATF
data. While ATF interprets its theft reporting requirement to mean that
state and local entities, among others, must report explosives thefts, ATF
officials acknowledged that state and local government entities may be
unclear as to whether they are covered under this requirement. Indeed,
during our site visits and other state and local contacts, we found
evidence of 5 thefts from state and local government facilities, 1 of
which did not appear in ATF's national database on thefts and missing
explosives.
Although state and local government explosives storage facilities must
comply with federal storage regulations, ATF does not have oversight
authority at these facilities. ATF oversight-including the ability to
conduct regulatory inspections-is linked to licensing, and state and local
government entities are not required under federal explosives law to
obtain such a license. ATF does not have specific statutory authority to
conduct regulatory inspections at these storage facilities. Through its
licensing and inspection authority, ATF is able to collect nationwide
information on the number and locations of private sector storage
facilities and the types and amounts of explosives being stored. Because
ATF does not license and inspect state and local government facilities, no
similar information is collected about them. On the basis of our audit
work, we identified three types of government entities that used and
stored explosives: (1) law enforcement bomb squads, (2) public
universities, and (3) state and local departments of transportation. We
were unable to gather sufficient information about these entities to
reliably estimate the total number of state and local government storage
facilities and magazines nationwide.
During our audit, we visited 14 state and local government entities-13
bomb squads and 1 public university-and observed the security measures in
place at their 18 explosives storage facilities. Regarding physical
security, most facilities had a locked gate to prevent vehicle access and
several had fencing surrounding their storage facilities. Several storage
facilities also had electronic security systems in place-such as video
surveillance. These types of security measures-fences, vehicle barriers,
and electronic monitoring devices-all exceed the requirements of federal
explosives regulations. Officials at all the entities we visited told us
they visually inspected or patrolled the facilities on a regular basis and
conducted routine inventories. Most facilities were not required to be
licensed or inspected by state or local regulatory agencies. Of the 5
explosives thefts we identified during our site visits and other contacts,
2 had occurred at state and local storage facilities we visited, but only
1 of these incidents appeared in ATF's nationwide theft database.
In our report released today, we recommend that the Attorney General
direct the ATF Director to clarify federal explosives regulations to
ensure that state and local government agencies understand their
obligation to report thefts or missing explosives. The Department of
Justice agreed with our recommendation and indicated it would take steps
to implement it.
ATF is the chief enforcer of explosives laws and regulations in the United
States and is responsible for licensing and regulating explosives
manufacturers, importers, dealers, and users.2 ATF is also responsible for
regulating most, but not all, explosives storage facilities. Under federal
explosives regulations, a license is required for persons who manufacture,
import, or deal in explosives and, with some exceptions, for persons who
intend to acquire explosives for use. No license is required solely to
operate an explosives storage facility. State and local government
agencies are not required to obtain an explosives license to use and store
explosives. However, all persons who store explosive materials (including
state and local entities) must conform with applicable ATF storage
regulations, irrespective of whether they are required to obtain an
explosives license for other purposes. According to ATF data, as of
February 2005 there were 12,028 federal explosives licensees in the United
2Licenses are issued to persons who manufacture, import, or sell
explosives, while permits are issued to persons who intend to acquire and
use explosives. Throughout the remainder of this statement, references to
explosives licenses, licensees, or ATF's licensing authority refer to both
explosives licenses and permits.
Background
States.3 Roughly 7,500 of these had some kind of explosives storage
facility, consisting of 22,791 permanent or mobile storage magazines.
ATF storage regulations include requirements relating to the safety and
security of explosives storage magazines-that is, any building or
structure (other than an explosives manufacturing building) used for
storage of explosive materials. Regarding safety, the storage regulations
include requirements related to location, construction, capacity,
housekeeping, interior lighting, and magazine repairs, as well as a
requirement that the local fire safety authority be notified of the
location of each storage magazine. Regarding security, the ATF storage
regulations include the following requirements:
o Explosives handling. All explosive materials must be kept in locked
magazines unless they are in the process of manufacture, being physically
handled in the operating process of a licensee or user, being used, or
being transported to a place of storage or use. Explosives are not to be
left unattended when in portable storage magazines.
o Magazine construction. Storage magazines must be theft-resistant and
must meet specific requirements dealing with such things as mobility,
exterior construction, door hinges and hasps, and locks.
o Magazine inspection. Storage magazines must be inspected at least
every 7 days. This inspection need not be an inventory, but it must be
sufficient to determine if there has been an unauthorized entry or
attempted entry into the magazines, or unauthorized removal of the
magazine contents.
o Magazine inventory. Within the magazine, containers of explosive
materials are to be stored so that marks are visible. Stocks of explosive
materials are to be stored so they can be easily counted and checked.
Notwithstanding the security requirements described above, ATF storage
regulations do not require explosives storage facilities to have any of
the following physical security features-fences, restricted property
access, exterior lighting, alarm systems, or electronic surveillance.
Also, while ATF licensing regulations require explosives licensees to
conduct a physical inventory at least annually, there is no similar
inventory requirement in the storage regulations applicable to other
persons who store explosives.
3Including the District of Columbia, Guam, Puerto Rico, and the Virgin
Islands.
Thefts Reported at State and Local Explosives Storage Facilities Are Few
but May Be Underreported
According to ATF data, the number of reported state and local government
thefts is relatively small when compared with the total number of thefts
that have occurred nationwide. During a recent 3-year period (January
2002-February 2005), ATF received reports of 205 explosives thefts from
all sources nationwide. By comparison, during this same period, only 9
thefts were reported that involved state and local government storage
facilities-5 involving state and local law enforcement agencies,4 3
involving state government entities (all universities), and 1 involving a
county highway department. The amounts of explosives reported stolen or
missing from state and local government facilities are relatively small
when compared with the total amounts of stolen and missing explosives
nationwide. During a recent 10-month period for which data were available
(March 2003 through December 2003), there were a total of 76 theft
incidents nationwide reported to ATF, amounting to a loss of about 3,600
pounds of high explosives, 3,100 pounds of blasting agents, 1,400
detonators, and 2,400 feet of detonating cord and safety fuse. By
comparison, over an entire 10-year period (January 1995 through December
2004), ATF received only 14 reports of theft from state and local law
enforcement storage magazines. Reported losses in these cases were about
1,000 pounds of explosive materials, and in 10 of the incidents less than
50 pounds of explosives was reported stolen or missing.
While the ATF theft data indicate that thefts from state and local
facilities make up only a small part of the overall thefts nationwide,
these reports could be understated by an unknown amount. There are two
federal reporting requirements relating to the theft of explosives. One is
specific to all federal explosives licensees (and permittees) and requires
any theft or loss of explosives to be reported to ATF within 24 hours of
discovery. The second reporting requirement generally requires any other
"person" who has knowledge of the theft or loss of any explosive materials
from his stock to report to ATF within 24 hours. Although the term
"person" as defined in law and regulation does not specifically include
state and local government agencies,5 ATF has historically interpreted
this requirement as applying to nonlicensed state and local government
explosives storage facilities. However, ATF officials acknowledged that
some state and local
4One of these was later determined to be the possible result of training
explosives that had been mistakenly discarded.
5The term "person" is defined in statute and regulation as "any
individual, corporation, company, association, firm, partnership, society,
or joint stock company" (see 18 U.S.C. S: 841(a); and 27 C.F.R. S:
555.11).
government entities could be unsure as to their coverage under the theft
reporting requirements and, as a result, may not know they are required to
report such incidents to ATF. Indeed, during our site visits and other
state and local contacts, we identified five state and local government
entities that had previously experienced a theft or reported missing
explosives- two involving local law enforcement agencies, two involving
state universities, and one involving a state department of
transportation.6 However, one of these five incidents did not appear in
ATF's nationwide database of reported thefts and missing explosives. Based
on these findings, the actual number of thefts occurring at state and
local government storage facilities nationwide could be more than the
number identified by ATF data.
ATF Lacks Authority to Regulate and Oversee State and Local Explosives
Storage Facilities Nationwide
There is no ATF oversight mechanism in place to ensure that state and
local government facilities comply with federal explosives regulations.
With respect to private sector entities, ATF's authority to oversee and
inspect explosives storage facilities is primarily a function of its
licensing process. However, state and local government entities are not
required to obtain a federal license to use and store explosives. In
addition, ATF has no specific statutory authority to conduct regulatory
inspections at state and local government storage facilities. Under
certain circumstances, ATF may inspect these facilities-for example,
voluntary inspections when requested by a state and local entity, and
mandatory annual inspections at locations where ATF shares space inside a
state and local storage magazine. Regarding those state and local
government facilities that ATF does not inspect, ATF officials
acknowledged they had no way of knowing the extent to which these
facilities are complying with federal explosives regulations.
ATF officials stated that if the agency were to be required to conduct
mandatory inspections at all state and local government storage
facilities, they would likely need additional resources to conduct these
inspections because they are already challenged to keep up with
inspections that are mandated as part of the explosive licensing
requirements. Under provisions of the Safe Explosives Act, ATF is
generally required to physically inspect a license applicant's storage
facility prior to issuing a federal explosives license-which effectively
means at least one inspection every 3 years. At the same time, however,
ATF inspectors are
6Two of these five incidents occurred at locations we visited; three
occurred at other locations we identified during the course of our audit
work.
also responsible for conducting inspections of federal firearms licensees.
The Department of Justice Inspector General reported that ATF has had to
divert resources from firearms inspections to conduct explosives storage
facility inspections required under the Safe Explosives Act. Despite
recent funding increases for ATF's explosives program, giving ATF
additional responsibility to oversee and inspect state and local
government storage facilities could further tax the agency's inspection
resources. According to ATF officials, because inspection of explosives
licensees is legislatively mandated, the effect of additional state and
local government explosives responsibilities (without related increases in
inspector resources) could be to reduce the number of firearms inspections
that ATF would be able to conduct.
ATF does not collect nationwide information on the number and location of
state and local government explosives storage facilities, nor does the
agency know the types and amounts of explosives being stored in these
facilities. Since data collection is a function of the licensing process
and state and local facilities are not required to be licensed, no
systematic information about these facilities is collected. With respect
to private sector licensees, ATF collects descriptive information
concerning explosive storage facilities as part of the licensing process.
ATF license application forms require applicants to submit information
about their storage capabilities, including specific information about the
type of storage magazine, the location of the magazine, the type of
security in place, the capacity of the magazine, and the class of
explosives that will be stored. ATF also collects information about
licensed private sector storage facilities during mandatory inspections,
through examination of explosives inventory and sales records and
verification that storage facilities meet the standards of public safety
and security as prescribed in the regulations.
During the course of our audit work, we compiled some data on state and
local government entities that used and stored explosives. At the 13 state
and local law enforcement bomb squads we visited, there were 16 storage
facilities and 30 storage magazines. According to Federal Bureau of
Investigation data, there are 452 state and local law enforcement bomb
squads nationwide. However, because of the limited nature of our
fieldwork, we cannot estimate the total number of storage facilities or
magazines that might exist at other bomb squad locations. Moreover, other
state and local government entities (such as public universities and state
and local departments of transportation) in addition to law enforcement
bomb squads also have explosives storage facilities. At the one public
university we visited, there were 2 storage facilities and 4 storage
magazines. Again, however, because of the limited nature of our fieldwork,
we cannot estimate the total number of storage facilities and magazines that
exist at these other state and local government entities nationwide.
Security Measures Varied at State and Local Explosives Storage Facilities
We Visited
We found that security measures varied at the 14 state and local
government entities we visited. Overall, we visited, 2 state bomb squads,
11 city or county bomb squads (including police departments and sheriffs'
offices), and 1 public university. Four of the 14 state and local entities
had 2 separate storage areas, resulting in a total of 18 explosives
storage facilities among the 14 entities. Three of these storage
facilities were located on state property, 7 were located at city or
county police training facilities, 7 were located on other city or county
property, and 1 was located at a metropolitan airport. Eleven of the 18
explosives storage facilities we visited contained multiple magazines for
the storage of explosives. As a result, these 18 facilities comprised a
total of 34 storage magazines. All of the 18 facilities contained a
variety of high explosives, including C-4 plastic explosive, detonator
cord, TNT, binary (two-part) explosives, and detonators. Estimates of the
amount of explosives being stored ranged from 10 to 1,000 pounds, with the
majority of the entities (9) indicating they stored 200 pounds or less.
At each of the 14 state and local storage entities we visited, we observed
the types of security measures in place at their explosives storage
facilities. Our criteria for identifying the type of security measures in
place included existing federal explosives storage laws and regulations
(27 C.F.R., Part 555, Subpart K) and security guidelines issued by the
explosives industry (the Institute of Makers of Explosives). Most of these
security measures (fencing, vehicle barriers, and electronic surveillance,
for example) are not currently required under federal storage regulations.
However, we are presenting this information in order to demonstrate the
wide range of security measures actually in place at the time of our
visits.
o Physical security. Thirteen of the 18 storage facilities restricted
vehicle access to the facility grounds by way of a locked exterior
security gate or (in one case) by virtue of being located indoors. Five of
the 13 facilities restricted vehicle access after normal working hours
(nights or nights and weekends). Officials at 7 other facilities said that
vehicle access to the facilities was restricted at all times, including
the 1 indoor facility that was located in the basement of a municipal
building. Six of the 18 storage facilities had an interior
barrier-consisting of a chain-link fence with a locked gate-immediately
surrounding their storage magazines to prevent direct access by persons on
foot. One other facility (the indoor basement facility), relied on
multiple locked doors to prevent access by unauthorized personnel.
Conversely, at 1 facility we visited, the storage
magazine could be reached on foot or by vehicle at any time because it did
not have fencing or vehicle barriers to deter unauthorized access. In
addition to restricted access to storage facilities, officials at all of
the 18 storage facilities we visited told us that official
personnel-either bomb squad or other police officers-patrolled or
inspected the storage facility on a regular basis. And, at 9 of the 18
storage facilities we visited, officials said that state or local
government employees-police training personnel, jail or correctional
personnel, or other city/county employees-maintained a 24-hour presence at
the facilities.
o Electronic security. Four of the 18 explosives storage facilities had
either an alarm or video monitoring system in place. Two storage
facilities with video surveillance took advantage of existing monitoring
systems already in place at their storage locations-one located at a
county correctional facility and one located inside a municipal/police
building. Officials at 4 storage facilities told us they had alarm systems
planned (funding not yet approved), and officials at 3 facilities said
they had alarm systems pending (funding approved and awaiting
installation). Officials at 2 facilities also told us they planned to
install video monitoring. Regarding the feasibility of installing
electronic monitoring systems, 4 officials noted that storage facilities
are often located in remote areas without easy access to electricity.
Regarding the possibility of new federal regulations that would require
electronic security at storage magazines, 9 officials told us they would
not object as long as it did not create an undue financial burden.
o Inventory and oversight issues. Officials at all 14 of the entities we
visited told us they performed periodic inventories of the contents of
their explosives storage magazines in order to reconcile the contents with
inventory records. In addition, 9 entities said they had received
inspections of their storage facilities, primarily by ATF. Six entities
told us they received the inspections on a periodic basis, with another 3
entities having received a onetime inspection. Regarding oversight by
multiple regulatory authorities, one entity had been inspected by both ATF
and a local government authority, while another entity was inspected on a
recurring basis by both ATF and a state government authority. Five of the
14 entities we visited told us they were required to obtain a license from
state regulatory authorities to operate their explosives storage
facilities. One of these entities was also required (by the state
regulatory authority) to obtain a federal explosives license issued by
ATF. Officials at 13 entities we visited said they did not object to the
possibility of federal licensing or inspection of their explosives storage
facilities. Officials at 3 state and local entities noted that additional
federal oversight was not a concern as long as they were not held to a
higher standard of security and safety than ATF requires of private
industry.
o
Conclusions and Recommendations
Thefts and compliance issues. Two of the five thefts we documented during
our site visits and other state and local contacts occurred at state and
local entities we visited. At one storage facility, officials told us that
criminals had once used a cutting torch to illegally gain entry to an
explosives storage magazine. At another storage facility, officials said
that an unauthorized individual had obtained keys to a storage magazine
and taken some of the explosives. In both incidents, the perpetrators were
apprehended and the explosives recovered. However, one of these incidents
did not appear in ATF's nationwide database of reported thefts and missing
explosives. We also observed storage practices at four facilities that may
not be in compliance with federal explosives regulations. However, these
circumstances appeared to be related to storage safety issues, rather than
storage security. In April 2005, the National Bomb Squad Commanders
Advisory Board-which represents more than 450 law enforcement bomb squads
nationwide-initiated a program encouraging bomb squads to request a
voluntary ATF inspection, maintain an accurate explosives inventory, and
assess the adequacy of security at their explosive storage facilities to
determine if additional measures might be required (such as video
monitoring, fencing, and alarms). This is a voluntary program and it is
too soon to tell what effect, if any, it will have towards enhancing
security at state and local law enforcement storage facilities and
reducing the potential for thefts.
The overall number of state and local government explosives storage
facilities, the types of explosives being stored, and the number of
storage magazines associated with these facilities are currently not known
by ATF. ATF has no authority to oversee state and local government storage
facilities as part of the federal licensing process, nor does it have
specific statutory authority to conduct regulatory inspections of these
facilities. As a result, ATF's ability to monitor the potential
vulnerability of these facilities to theft or assess the extent to which
these facilities are in compliance with federal explosives storage
regulations is limited.
According to ATF's interpretation of federal explosives laws and
regulations, state and local government agencies-including law enforcement
bomb squads and public universities-are required to report incidents of
theft or missing explosives to ATF within 24 hours of an occurrence.
Because this reporting requirement applies to any "person" who has
knowledge of a theft from his stock and the definition of "person" does
not specifically include state and local government agencies, ATF
officials acknowledged that these entities may be unsure as to whether
they are required to report under this requirement. If state and local
government entities are unsure about whether they are required to report
thefts and missing explosives, ATF's ability to monitor these incidents
and take appropriate investigative action may be compromised by a
potential lack of information. Further, the size of the theft problem, and
thus the risk, at state and local government storage facilities will
remain unclear.
To allow ATF to better monitor and respond to incidents of missing or
stolen explosives, the report we are releasing at this hearing recommends
that the Attorney General direct the ATF Director to clarify the
explosives incident reporting regulations to help ensure that all persons
and entities who store explosives, including state and local government
agencies, understand their obligation to report all thefts or missing
explosives to ATF within 24 hours of an occurrence. The Department of
Justice agreed with our recommendation and said it would take steps to
implement it.
Contact and Staff Acknowledgments
(440462)
Mr. Chairman, this concludes my prepared statement. I would be happy to
respond to any questions that you or members of the subcommittee may have.
For information about this testimony, please contact Laurie E. Ekstrand,
Director, Homeland Security and Justice Issues, at (202) 512-8777, or
[email protected]. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this
testimony. Other individuals making key contributions to this testimony
include William Crocker, Assistant Director; Philip Caramia; and Michael
Harmond.
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