Combating Terrorism: Opportunities To Improve Domestic Preparedness
Program Focus and Efficiency (Letter Report, 11/12/98, GAO/NSIAD-99-3).

Pursuant to a legislative requirement, GAO reviewed the status and other
aspects of the Domestic Preparedness Program, focusing on: (1) the
training and other benefits offered to cities under the program; and (2)
the methodology for designing and implementing the program, including
the way in which cities were selected to participate, how cities'
capabilities and needs were assessed, and the effectiveness of
interagency coordination on this and other similar consequence
management training and equipment programs.

GAO noted that: (1) the training and equipment that the Department of
Defense (DOD) is providing to cities through the Domestic Preparedness
Program have clearly increased cities' awareness of and should better
prepare them to deal with a potential chemical or biological terrorist
incident; (2) local officials in the seven cities GAO visited praised
the training program's content, instructors, and materials as well as
DOD's willingness to modify the program based on suggestions from local
officials; (3) they also credited the program with bringing local,
state, and federal regional emergency response agencies together into a
closer working relationship; (4) in designing the training and equipment
program, DOD selected 120 cities based solely on city population; (5)
this decision resulted in 14 clusters of 44 cities within 30 miles of at
least one other city selected; (6) by dealing with cities, DOD did not
build upon the states' existing emergency management and training
structures; (7) had it used existing structures that reflect how
emergency response is actually organized, DOD could have consolidated
training and equipment purchases to cover more jurisdictions in fewer
locations than presently planned, at less cost; (8) DOD's loan of
equipment in support of the training program has caused frustration and
confusion among local officials; (9) the legislation authorized DOD to
lend equipment to local jurisdictions, and DOD established a 5-year
renewable loan agreement to govern the provision of about $300,000 worth
of equipment to each city; (10) this agreement restricts the use of the
equipment to training rather than operational purposes and requires the
cities to repair, maintain, and replace the equipment; (11) cities were
concerned about the lack of federal sustainment money to maintain,
repair, and replace the equipment; (12) the program has raised
expectations among some local officials that the federal government may
provide additional funding for operational equipment; (13) the
interagency coordination process provided a valuable information-sharing
forum but was of limited success in helping steer the design and
development of the program; (14) federal agencies' individual efforts to
enhance consequence management of possible incidents involving weapons
of mass destruction (WMD) terrorism are not guided by an overarching
strategy for achieving a defined end state; and (15) local officials in
most of the cities raised the issue that the many WMD training,
equipment, and consequence management programs are evidence of a
fragmented and wasteful federal approach toward combating terrorism.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-99-3
     TITLE:  Combating Terrorism: Opportunities To Improve Domestic 
             Preparedness Program Focus and Efficiency
      DATE:  11/12/98
   SUBJECT:  Terrorism
             Emergency preparedness
             Government owned equipment
             Interagency relations
             Mobilization
             Training utilization
             Technical assistance
             National defense operations
             Nuclear weapons
IDENTIFIER:  Nunn-Lugar-Domenici Domestic Preparedness Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

November 1998

COMBATING TERRORISM -
OPPORTUNITIES TO IMPROVE DOMESTIC
PREPAREDNESS PROGRAM FOCUS AND
EFFICIENCY

GAO/NSIAD-99-3

Combating Terrorism

(701125)


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense
  CBDCOM - Chemical and Biological Defense Command
  FBI - Federal Bureau of Investigation
  FEMA - Federal Emergency Management Agency
  MMST - Metropolitan Medical Strike Team
  PHS - Public Health Service
  WMD - weapons of mass destruction

Letter
=============================================================== LETTER


B-278556

November 12, 1998

The Honorable Ike Skelton
Ranking Minority Member
Committee on National Security
House of Representatives

The Honorable J.  Dennis Hastert
Chairman, Subcommittee on National Security,
 International Affairs and Criminal Justice
Committee on Government Reform and Oversight
House of Representatives

Concerned that terrorists might move beyond using conventional
weapons to weapons of mass destruction (WMD)--chemical, biological,
radiological, or nuclear devices--Congress authorized the federal
government to improve capabilities to respond to such incidents,
particularly at the local level.  As requested, we reviewed the
status and other aspects of the Domestic Preparedness Program, a
training, assistance, and equipment loan program led by the
Department of Defense (DOD).  Specifically, we evaluated (1) the
training and other benefits offered to cities under the Domestic
Preparedness Program and (2) the methodology for designing and
implementing the program, including the way in which cities were
selected to participate, how cities' capabilities and needs were
assessed, and the effectiveness of interagency coordination on this
and other similar consequence management training and equipment
programs.  You also asked us to determine the potential cost of
equipping and maintaining the capability of a city to respond to a
terrorist incident involving WMD.  This matter will be the subject of
a report to be issued later. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The training and equipment that DOD is providing to cities through
the Domestic Preparedness Program have clearly increased cities'
awareness of and should better prepare them to deal with a potential
chemical or biological terrorist incident.  Local officials in the
seven cities we visited praised the training program's content,
instructors, and materials as well as DOD's willingness to modify the
program based on suggestions from local officials.  They also
credited the program with bringing local, state, and federal regional
emergency response agencies together into a closer working
relationship. 

In designing the training and equipment program, DOD selected 120
cities based solely on city population.  This decision resulted in 14
clusters of 44 cities within 30 miles of at least 1 other city
selected.  By dealing directly with cities, DOD did not build upon
the states' existing emergency management and training structures. 
Had it used existing structures such as counties, response regions,
mutual aid agreements, or other similar arrangements that reflect how
emergency response is actually organized, DOD could have consolidated
training and equipment purchases to cover more jurisdictions in fewer
locations than presently planned, at less cost.  Because less than
one-third of the cities had received training at the time of our
review, DOD or any subsequent lead agency could still refocus its
approach for greater efficiency, economy, and effectiveness. 

DOD's loan of equipment in support of the training program has caused
frustration and confusion among local officials.  The legislation
authorized DOD to lend rather than give or grant equipment to local
jurisdictions, and DOD established a 5-year renewable loan agreement
to govern the provision of about $300,000 worth of equipment to each
city.  This agreement restricts the use of the equipment to training
and requires the cities to repair, maintain, and replace the
equipment, even though DOD program officials intend for the loans to
be permanent and will allow the use of equipment for operational
purposes.  Cities were concerned about the lack of federal
sustainment money to maintain, repair, and replace the equipment. 
Also, the program has raised expectations among some local officials
that the federal government may provide additional funding for
operational equipment. 

The interagency coordination process provided a valuable
information-sharing forum but was of limited success in helping steer
the design and development of the program.  According to some Senior
Interagency Coordination Group members, DOD did not heed their advice
on designing the program.  For example, DOD did not adequately
leverage existing training programs.  However, the Group did
influence the timing of the first cities to be trained.  The Group
also disapproved of DOD's method of assessing the 120 cities' needs
or requirements but did not develop an acceptable alternative
assessment approach.  No threat and risk assessment\1 was applied to
help determine cities' requirements or needs or to establish a
roadmap or defined end state of preparedness.  While it is not
possible to eliminate or reduce the risk to all potential targets
against WMD terrorism, threat and risk assessments can help ensure
that localities receive the most appropriate training and equipment
based on the level of protection desired. 

Federal agencies' individual efforts to enhance consequence
management of possible incidents involving WMD terrorism are not
guided by an overarching strategy for achieving a defined end state. 
Local officials in most of the cities we visited raised the issue
that the many WMD training, equipment, and consequence management
programs are evidence of a fragmented and possibly wasteful federal
approach toward combating terrorism.  Cities pointed to similar
federal agency training and equipment programs, such as those offered
by the Department of Justice and FEMA and the new initiative to give
the National Guard a WMD response role, as examples of the unfocused
federal approach to combating terrorism. 


--------------------
\1 Combating Terrorism:  Threat and Risk Assessments Can Help
Prioritize and Target Program Investments (GAO/NSIAD-98-74, Apr.  9,
1998). 


   BACKGROUND
------------------------------------------------------------ Letter :2

Concerned that WMD are increasingly available to terrorists, Congress
passed the Defense Against Weapons of Mass Destruction Act of 1996,
commonly known as the Nunn-Lugar-Domenici Act (P.L.  104-201, Sept. 
23, 1996).  The act designates DOD as the lead agency to enhance
domestic preparedness for responding to and managing the consequences
of terrorists' use of WMD.\2 Under the act, DOD can provide training,
exercises, and expert advice to emergency response personnel and lend
equipment to local jurisdictions. 

The Secretary of Defense designated the Assistant Secretary for
Special Operations and Low-Intensity Conflict as the policy office
and the Secretary of the Army to carry out the Domestic Preparedness
Program.  Because of its subject matter expertise, the Army's
Chemical and Biological Defense Command (CBDCOM) was tasked to
implement the program through the Army Director of Military Support. 
The Director of Military Support and CBDCOM designed a training
program to build on the existing knowledge and capabilities of those
who would first deal with a WMD incident locally--fire, law
enforcement, and medical personnel and hazardous materials
technicians.  This generally week-long program takes a
train-the-trainer approach.  On the last day of the week-long
program, local officials role-play their responses to a specific
terrorism scenario through a tabletop exercise.  The act also
authorizes (1) funds for DOD to assist the Secretary of Health and
Human Services in establishing Metropolitan Medical Strike Teams
(MMST) to help improve local jurisdictions' medical response
capabilities for a WMD incident; (2) a telephonic link to provide
data and expert advice for the use of state and local officials
responding to emergencies involving WMD; (3) a rapid response
information system, including an inventory of rapid response assets
and a database on chemical and biological materials; and (4) a
chemical/biological rapid response team. 

Agencies that participate in the program include the Federal
Emergency Management Agency (FEMA), the Federal Bureau of
Investigation (FBI), the Department of Energy, the Department of
Health and Human Services' Public Health Service (PHS), and the
Environmental Protection Agency.  The act also requires that DOD
coordinate with state and local emergency preparedness agencies. 
Until June 1998, the coordinating body for the Domestic Preparedness
Program was the Senior Interagency Coordination Group on Terrorism.\3

DOD received $36 million in fiscal year 1997 to implement the
program.  An additional $6.6 million was provided for PHS to
establish medical strike teams.  DOD's fiscal year 1998 and 1999
budget estimates are $43 million and $50 million, respectively, to
continue the program.  DOD estimates that the last 2 years of the
5-year program will cost about $14 million to $15 million each year. 
DOD expects its portion of the 5-year program to cost at least $157
million, but it expects to incur costs of about $5 million per year
in fiscal years 2002 and 2003 to conduct program-related exercises. 
Appendixes I through III show more detailed actual and projected DOD
Domestic Preparedness Program costs for fiscal years 1997-99. 


--------------------
\2 Training for consequence management would include measures to
alleviate damage, loss of life, or suffering; protect public health
and safety; restore essential government services; and provide
emergency assistance. 

\3 In March 1998, FEMA, which established and chaired the Senior
Interagency Coordination Group, withdrew from the Group.  Currently,
a National Security Council working group under the new National
Coordinator for Security, Infrastructure Protection and
Counter-Terrorism--a position established in May 1998 by Presidential
Decision Directive 62--is responsible for interagency coordination. 


   CITIES BENEFIT FROM DOMESTIC
   PREPAREDNESS PROGRAM
------------------------------------------------------------ Letter :3

Cities that have received training under the Domestic Preparedness
Program have a greater awareness of how to respond to a potential
chemical or biological terrorist incident.  Local officials praised
the training program content, instructors, and materials as well as
DOD's willingness to act on constructive criticism and adjust the
courses.  They also credited the program with bringing local, state,
and federal regional emergency response agencies together into a
closer working relationship.  By December 31, 1998, DOD expected to
have trained about one-third of the 120 cities it selected for the
program and planned to complete the entire training program by fiscal
year 2001.  Those trained--fire fighters, hazardous materials
technicians, emergency medical services personnel, law enforcement
personnel, hospital personnel, and dispatchers--are expected to train
other emergency responders through follow-on courses.  The seven
cities we visited were planning to institutionalize various
adaptations of the WMD training, primarily in their fire and law
enforcement academies.  A related exercise program to allow cities to
test their response capabilities also has begun.  As authorized under
the Nunn-Lugar-Domenici legislation, DOD is in the process of
providing $300,000 in training and operational equipment--personal
protection, detection, decontamination, and training aids\4
--selected by each city after it is trained.  As of June 1998, nine
cities had received equipment and other cities were developing their
lists.  See appendix IV for DOD's suggested equipment list. 


--------------------
\4 Training aids are a standard package provided by DOD.  Cities have
flexibility in selecting items from the other three equipment
categories as long as the items relate to WMD response.  Vehicles are
not among the authorized equipment items. 


      OTHER PROGRAM ASPECTS ARE
      BEING IMPLEMENTED
---------------------------------------------------------- Letter :3.1

The other aspects of the Domestic Preparedness Program either have
been implemented or are in process.  DOD established a hot line for
reporting incidents and requesting technical assistance through the
existing National Response Center for hazardous materials spills, and
a help line was established through which CBDCOM experts can provide
information and advice.  The Command also has an internet web site to
provide information on the Domestic Preparedness Program.  FEMA
established the Rapid Response Information System to allow federal
and state agencies controlled computer access to a database on
federal response capabilities, WMD substances, equipment, and other
information.  (An internet web site allows general access to an
abbreviated version of the system.) A number of city and state
officials we interviewed had limited knowledge about these
communications systems, and some were skeptical of their value during
a crisis.  These officials indicated that the systems seemed
redundant to existing emergency response reporting channels and
information sources, and they did not expect to take the time to use
any of these systems in the event of an incident. 

In association with the cities of Baltimore and New York, CBDCOM is
identifying ways to improve the response to chemical and biological
WMD incidents, respectively.  The Command is also testing first
responder equipment, such as protective clothing and chemical
detectors, to enable cities to make more informed decisions about
equipment purchases or requests through the DOD equipment program. 
At the time of our review, DOD had not finalized a joint command
structure for a Chemical/Biological Rapid Response Team, which is
intended to support federal, state, and local agencies in dealing
with a WMD incident.  The team will comprise existing military units
from more than one military service and possibly from National Guard
and Reserve units. 

PHS continues to establish and equip MMSTs for which the initial 27
program cities are developing concept of operations plans for medical
systems.  PHS has contracts with the 27 cities and expects them to
complete their plans, including how MMSTs are being incorporated into
the local emergency response and medical systems, by December 31,
1998.  At the time of our review, PHS further planned to establish
MMSTs in all 120 program cities.  These teams are eligible for
unmatched federal funding to acquire an average of $350,000 worth of
equipment, supplies, and pharmaceuticals based on the requirements
related to their concept of operations plans.\5


--------------------
\5 Unmatched federal funding for equipment, supplies, and
pharmaceuticals ranges from $300,000 for smaller cities to $800,000
for New York City.  All MMST cities are required to have sufficient
pharmaceutical stocks to initially treat at least 1,000 casualties. 
See appendix V for an example of the types of equipment being
acquired for MMSTs. 


   CITIES SELECTED BASED UPON
   POPULATION
------------------------------------------------------------ Letter :4

DOD decided to implement its Domestic Preparedness Program in the 120
largest U.S.  cities based on city population (1990 census, revised
Apr.  1995).\6 This equated to all U.S.  cities with more than
144,000 people at the time.  Figure 1 lists the cities DOD selected. 
The 120 cities represent about 22 percent of the U.S.  population and
cover at least 1 city in 38 states and the District of Columbia. 
Twelve states\7 and the U.S.  territories have no cities in the
program, and 25 percent of the cities are in California and Texas. 

   Figure 1:  Cities Selected for
   Domestic Preparedness Program
   (in order of population)

   (See figure in printed
   edition.)

\a Not a city government. 

Source:  U.S.  Army Chemical and Biological Defense Command. 

DOD took a city approach because it wanted to deal with a single
governmental entity that could select the most appropriate personnel
for training and to receive equipment.  But in selecting cities, DOD
did not take into account a city's existing level of preparedness or
financial need.  Also, DOD did no analysis to determine whether all
cities on the list actually had a perceptible level of threat and
risk of terrorism or whether a smaller city with high risk factors
might have been excluded from the program due to its lower
population.  No federal agency determined and assessed cities' risk
factors based on intelligence assessments, critical infrastructure
points, national symbols, future special events drawing large crowds,
sensitive government or corporate activities, or similar analyses and
data to help evaluate cities' key assets and vulnerabilities to WMD. 
In fact, in no city we visited did the FBI determine there was a
credible threat of a WMD attack, which would be one factor considered
in a threat and risk assessment.\8


--------------------
\6 The decision to select the most populated 120 cities was discussed
within the Senior Interagency Coordination Group. 

\7 Connecticut, Delaware, Idaho, Maine, Montana, New Hampshire, North
Dakota, South Carolina, South Dakota, Vermont, West Virginia, and
Wyoming. 

\8 Although the FBI and the intelligence community see growing
interest in WMD by groups and individuals of concern, the
intelligence community concluded that explosives or other
conventional weapons will continue to be the most likely form of
terrorist attack over the next decade. 


   LINKING FUTURE TRAINING TO
   EXISTING STRUCTURES WOULD BE
   MORE EFFICIENT AND ECONOMICAL
------------------------------------------------------------ Letter :5

DOD has set out to deliver training without taking advantage of
existing state emergency management structures, mutual aid agreements
among local jurisdictions, or other collaborative arrangements for
emergency response.  By delivering the program to cities based on
population size, DOD replicates training sessions in nearby cities
that also qualified for the program and might even be part of the
same response system or mutual aid jurisdiction.  Mutual aid
agreements, unified emergency service districts, councils of
government, hazardous materials response regions, and traditional
state roles in fire and emergency management training (as well as
links to the federal response system),\9 would allow DOD to
consolidate training and could result in far fewer training
iterations.  Training in fewer locations and taking advantage of
existing emergency response structures could hasten the
accomplishment of program goals and have the added benefit of
reinforcing local response integration.  Such an approach could also
cover a greater percentage of the population and make effective use
of existing emergency management training venues.  Under this
approach, WMD training could be delivered over the long term through
existing state training systems.  Table 1 compares the difference in
coverage that results from selecting 120 cities, counties, or
standard/primary metropolitan statistical areas. 



                                Table 1
                
                U.S. Population Covered Based on Size of
                             Area Selected

                                               Total     Percentage of
                                          population              U.S.
Size of area                                 of area        population
selected                                  (millions)           covered
----------------------------------  ----------------  ----------------
City population                                 54.9              22.0
County population                              108.9              43.6
Standard/primary metropolitan                  160.2              64.1
 statistical area
----------------------------------------------------------------------
Note:  Largest 120 areas based on 1990 census, updated 1994-95. 

Table 2 shows that DOD could have selected fewer areas to cover 22
percent of the population. 



                                Table 2
                
                Areas Needed to Cover 22 Percent of the
                    U.S. Population, by Type of Area

Type of area selected                 Total area
--------------------------------  --  --------------------------------
City                                  120 cities
County                                24 counties
Standard/primary metropolitan         12 statistical areas
 statistical area
----------------------------------------------------------------------
DOD's approach resulted in clusters of program cities, each of which
is to receive training and equipment.  Figure 2 shows the location of
the cities nationwide and the clustering effect resulting from DOD's
decision to base training delivery on city population. 

   Figure 2:  Clustering of Cities
   Selected for Domestic
   Preparedness Program

   (See figure in printed
   edition.)



   (See figure in printed
   edition.)

Note:  City locations are approximate. 

Source:  U.S.  Army Chemical and Biological Defense Command. 

Figure 3 shows 14 clusters of 44 different cities within 30 miles of
at least 1 other program city, or 37 percent of the total number of
cities, that DOD selected for the program.  Increasing the distance
to 60 miles between cities produces 18 clusters involving 58 cities,
or nearly half of the total number of cities in the program. 

   Figure 3:  Program Cities
   Within 30 Miles of Another
   Program City

   (See figure in printed
   edition.)



   (See figure in printed
   edition.)

\a Driving distance, city center to city center. 

Source:  GAO analysis, based on mileage from GeoSystems Global
Corporation, Inc. 

The Southern California area shows the greatest effect of clustering. 
Under the California Standardized Emergency Management System, there
are countywide operational areas within six mutual aid regions (see
fig.  4). 

   Figure 4:  California's Mutual
   Aid Regions

   (See figure in printed
   edition.)

   Source:  California State
   Emergency Management System
   Guidelines.

   (See figure in printed
   edition.)

In Los Angeles County, the sheriff is in charge of the consolidated
interagency response to an incident occurring in any of the 88 cities
and 136 unincorporated areas within the county.  The Los Angeles
county operational area includes the cities of Los Angeles, Long
Beach, and Glendale, all of which are treated as separate entities in
the Domestic Preparedness Program.  Further, the nearby cities of
Anaheim, Huntington Beach, Santa Ana, San Bernardino, and Riverside
are within 30 miles of at least one other program city and are also
treated as separate entities.  Through mutual aid and under
California's statewide system, Los Angeles county could conceivably
assist or be assisted by these other neighboring cities or any other
jurisdictions in the state in the event of a major incident. 

Similarly, as shown in figure 5, Virginia has 13 regionalized
hazardous materials teams to respond to a WMD incident.  Through
these regional teams that operate under state control, four adjacent
program cities--Norfolk, Virginia Beach, Newport News, and
Chesapeake--could assist one another in the event of a WMD incident. 

   Figure 5:  Virginia's Regional
   Hazardous Materials Response
   Teams

   (See figure in printed
   edition.)

Texas has four program cities less than 30 miles from each other: 
Dallas, Fort Worth, Irving, and Arlington.  And the Washington, D.C.,
MMST is based on a metropolitan area council of governments agreement
involving six jurisdictions (and two program cities) in Virginia,
Maryland, and the District of Columbia that would support Washington,
D.C., or other metropolitan area first responders in the event of a
WMD incident.  MMSTs in other cities are also designed to be
integrated into the local emergency response and medical systems for
that particular area. 

In response to comments by state and local officials, DOD began
holding regional meetings to introduce the program.  Nevertheless,
each program city still receives its own training program and
training equipment package.  Cities may invite representatives from
neighboring jurisdictions and state agencies, but classroom space
tends to be limited, and if the neighboring city is a program city,
it will eventually receive its own on-site training. 

States have existing training structures that DOD could have used to
deliver its training courses.  California's Specialized Training
Institute, for example, provides emergency management training to
first responders statewide.  In Texas, the state's Division of
Emergency Management conducts training for local first responders,
and fire protection training is provided through the Texas
Engineering Extension Service.  FEMA said that it delivers numerous
courses through and in cooperation with state and local fire training
academies and emergency managers. 

Under current circumstances, it is up to the individual cities whose
personnel were trained as trainers to ensure the appropriate courses
are delivered to the rank-and-file emergency response personnel. 
Cities we visited were adapting the DOD courses differently and used
different venues to deliver the training.  Cities plan to deliver the
courses through their local academies and in most cases will also
deliver the courses directly.  One delivery method that DOD could
consider to reach large numbers of first responders while minimizing
travel costs is distance learning.  For example, the U.S.  Army
Medical Research Institute of Infectious Diseases has successfully
used distance learning techniques through satellite-to-television
links, and FEMA provides training to emergency responders nationwide
through its Emergency Education Network.  CBDCOM has been considering
distance learning technology to provide training to cities other than
the 120 selected for the Domestic Preparedness Program but is not
using it to train first responders in multiple cities in the existing
program. 


--------------------
\9 Federal, state, and local responders have a well-established
command structure that can expand and contract as needed.  FEMA uses
this incident command structure in disaster response to coordinate
activities with state and local authorities. 


   TERMS OF DOD EQUIPMENT
   AGREEMENT CONCERN CITIES
------------------------------------------------------------ Letter :6

Because of the Nunn-Lugar-Domenici legislative language authorizing
DOD to lend equipment (50 U.S.C.  2312 (e)), DOD provided equipment
as a 5-year renewable loan for training purposes rather than giving
or granting equipment to the cities.  DOD's loan agreement terms have
caused frustration and confusion among local officials.  Under the
terms of the loan agreement, cities are to repair, maintain, and
replace the equipment and are to use it only for training purposes. 
Officials from some cities we visited viewed the acceptance of the
equipment as tantamount to an unfunded federal mandate because DOD is
providing no funds to sustain the equipment.  At least two cities
were reluctant to accept the equipment unless DOD would assure them
that the equipment could be used operationally and that DOD did not
intend for the equipment to be returned.  Although such assurances
contradict the loan agreement, DOD program officials acknowledged
that DOD will not require cities to repair, maintain, replace, or
return the equipment and that cities can use it for operational
purposes as well as for training.  DOD officials also pointed out
that much of the equipment has no more than a 5-year useful life and
is largely incompatible with standard military-specification
equipment. 

Further, expectations have been raised among some local officials
that the federal government may eventually provide funds to sustain
the program, if not to provide even more equipment toward meeting
cities' perceived operational requirements.  DOD officials said that
the $300,000 equipment package was intended only for cities' training
needs.  Also, DOD wanted to encourage cities to share in the burden
of preparing for WMD terrorism by funding additional equipment
themselves.  DOD's basis for determining the $300,000 value of the
equipment program and allowing all cities the same amount, regardless
of their existing capabilities or financial need, is unclear and
undocumented.  Moreover, no federal agency has made assessments as a
part of the program to help determine requirements needed for WMD
over and above what is needed for a response to an industrial
hazardous materials incident. 


   INTERAGENCY COORDINATION HAS
   BEEN LIMITED
------------------------------------------------------------ Letter :7

Congress intended the Domestic Preparedness Program to be an
interagency effort with DOD as lead agency.  Under FEMA leadership,
the Senior Interagency Coordination Group provided a forum for DOD
and the other involved agencies to share information.  However, in
developing the program, some member agency officials stated that DOD
did not always take advantage of the experience of agencies that were
more accustomed to dealing with state and local officials and were
more knowledgeable of domestic emergency response structures.  For
example, some agency representatives said that they offered
suggestions such as taking a metropolitan area approach and
coordinating with state emergency management agencies instead of
dealing directly and only with cities.\10 DOD made most program
decisions and presented them to the Group for discussion.  According
to DOD, the Group was often unable to form consensus or reach a
decision, DOD was obligated to move forward with the program without
interagency agreement. 

According to participants, the Group did influence two decisions. 
DOD initially planned to cover 20 cities in the first phase of the
program, but the Group raised the number to 27 and gave 7 cities
higher priority in terms of timing for the training than their
population would otherwise warrant.  The Group made this decision to
account for special events, geographical balance, and the remoteness
of Honolulu, Hawaii, and Anchorage, Alaska, from the continental
United States.  Also, concerned about an assessment guide that DOD
developed for the cities and cities' presumed negative perceptions,
the Group recommended that DOD abandon its plan to have cities
conduct formal self-assessments of their capabilities and needs.  The
Group did not press for a more acceptable assessment methodology,
which resulted in the lack of any analytical basis for cities to
determine their requirements for a prudent and affordable level of
preparedness for WMD or to guide DOD in defining individual cities'
requirements. 

In addition, the Senior Interagency Coordination Group did not
resolve the issue of similar or potentially overlapping
terrorism-related courses.  Some agency officials told us that in
developing its training program, DOD did not take advantage of
existing terrorism-related courses or curriculums.  For example, a
joint Department of Justice and FEMA 2-day basic concepts course on
emergency response to terrorism was being developed at about the same
time as the Domestic Preparedness Program.  Department of Justice
officials described the course as being more detailed and technical
than the WMD awareness portion of the 5-day DOD program.  They said
that the training materials were available if DOD had wanted to use
them for the awareness and operations modules of its training
program, but a DOD program official said that the materials were
draft at the time and could not be used. 

FEMA and Department of Justice officials said they made available to
DOD materials from existing Emergency Management Institute and
National Fire Academy courses or workshops on terrorism-related
subjects.  Other federal agencies also have training that includes
WMD or other terrorism-related topics.  DOD did not adopt these
materials, and the Department of Justice and FEMA continued
developing additional terrorism-related courses as well.  Some city
and state officials and national first responder organizations
faulted DOD for not seeking their input or heeding their advice in
the early stages of program development so that DOD could have a
better appreciation of state and local emergency management and
training structures and incident command systems.\11


--------------------
\10 The International Association of Fire Chiefs said that it also
recommended a metropolitan area approach, given that many fire
departments are countywide.  Another firefighter organization
criticized DOD's city approach because it excludes large numbers of
first responders in smaller jurisdictions. 

\11 DOD did include local representatives in discussion groups used
to help establish training objectives. 


   STRATEGY NEEDED TO COORDINATE
   AND FOCUS MULTIPLE TRAINING,
   EQUIPMENT, AND RESPONSE
   ELEMENTS
------------------------------------------------------------ Letter :8

Some local officials viewed the growing number of WMD consequence
management training programs, including the Domestic Preparedness
Program, the Department of Justice and FEMA courses, FEMA Emergency
Management Institute courses, National Fire Academy courses, and a
National Guard Bureau's National Interagency Counterdrug Institute
course, as evidence of a fragmented and possibly wasteful federal
approach toward combating terrorism.  Similarly, multiple programs
with equipment segments--such as the separate DOD and PHS initiatives
and the new Department of Justice equipment grant program--are
causing frustration and confusion at the local level and are
resulting in further complaints that the federal government is
unfocused and has no coordinated plan or defined end state for
domestic preparedness.\12

The DOD and PHS equipment segments of the Domestic Preparedness
Program, which were designed and implemented separately, overlap as
both include personal protection, decontamination, and detection
equipment.  The separation of the DOD equipment and, where
applicable, the PHS equipment, supplies, and pharmaceuticals required
local officials to develop separate equipment lists and to ensure
compatibility and interoperability of the equipment, optimize the
available federal funding, and avoid unnecessary duplication.  This
was particularly important because the two equipment initiatives
overlap.  According to the Office of the Assistant Secretary of
Defense for Special Operations and Low-Intensity Conflict, DOD
intentionally separated the two equipment segments of the program.  A
joint, coordinated equipment program could have alleviated the
administrative burden on city officials and lowered the level of
confusion and frustration.  Although PHS circulated cities' proposed
equipment lists among the Domestic Preparedness Program's interagency
partners for comments, this coordination at the federal level did
little to simplify the process for the cities. 

The separation of the two equipment packages also required local
officials to deal with two federal agencies' differing requirements
and procedures.  Since the PHS equipment program is offered through a
contract with unmatched federal funds, the cities had to meet certain
requirements, including the development of a concept of operations
plan for MMSTs to fit into the local area's overall medical response
system.  The DOD equipment loan program required a different process. 
Other equipment initiatives, such as a new Department of Justice
equipment grant program, may add to the local governments' perception
of an unfocused federal strategy. 

State and local officials and some national firefighter organizations
also raised concerns about the growing number of federal response
elements being formed, including the new initiative to train and
equip National Guard units for a WMD response role.  These officials
did not believe specialized National Guard units would be of use
because they could not be on site in the initial hours of an incident
and numerous other military and federal agency support units can
already provide assistance to local authorities as requested.  These
units include the Army's Technical Escort Unit, the Marine Corps'
Chemical Biological Incident Response Force, and the PHS' National
Medical Response Teams.\13 State and local officials were more
supportive of the traditional National Guard role in providing
requested disaster support through the state governor.  We are
currently reviewing the proposed role of the National Guard and
reserves in WMD consequence management. 

As noted in our December 1997 report and in our April 1998 and
October 1998 testimonies, the many and increasing number of
participants, programs, and activities in the counterterrorism area
across the federal departments, agencies, and offices pose a
difficult management and coordination challenge to avoid duplication,
fragmentation, and gaps.  Recent interagency coordination initiatives
to deal with the increasing number of consequence management training
and equipment programs are underway both within and outside the
National Security Council.  A key proposal involves the transfer of
the Nunn-Lugar-Domenici Domestic Preparedness Program to the
Department of Justice.  We did not examine the effectiveness of these
coordination efforts or the details of the proposed transfer of the
program to the Department of Justice. 


--------------------
\12 In Combating Terrorism:  Observations on Crosscutting Issues
(GAO/T-NSIAD-98-164, Apr.  23, 1998) and Combating Terrorism: 
Observations on the Nunn-Lugar-Domenici Domestic Preparedness Program
(GAO/T-NSIAD-99-16, Oct.  2, 1998), we testified before the
Subcommittee on National Security, International Affairs and Criminal
Justice, House Committee on Government Reform and Oversight, on the
growing number of players in the counterterrorism arena and the need
for improved interagency coordination.  Also, in Combating Terrorism: 
Spending on Governmentwide Programs Requires Better Management and
Coordination (GAO/NSIAD-98-39, Dec.  1, 1997), we recommended that
governmentwide priorities for terrorism-related spending be
established and that resources be allocated based on the established
priorities and assessments of the threat and risk of terrorist
attack. 

\13 For a more comprehensive overview of federal support
capabilities, see Combating Terrorism:  Federal Agencies' Efforts to
Implement National Policy and Strategy (GAO/NSIAD-97-254, Sept.  26,
1997). 


   CONCLUSIONS
------------------------------------------------------------ Letter :9

Because DOD has trained only about one-third of the program cities
and the FBI and the intelligence community conclude that conventional
weapons will be terrorists' weapons of choice for the next decade,
there is adequate time to refocus the Domestic Preparedness Program
and to conduct the threat and risk assessments recommended in our
April 1998 report.  DOD or any subsequent lead agency could improve
the efficiency, economy, and effectiveness of the Domestic
Preparedness Program if it consolidated training on a more regional
basis, particularly where it will reinforce existing state, mutual
aid, and other similar multijurisdictional emergency response
structures.  The program could also benefit from involvement of the
states, particularly where state or regional training structures are
in place and could be leveraged to provide first responder training. 
Additionally, the Nunn-Lugar-Domenici legislative language providing
for the loan of equipment could allow for greater flexibility, given
the issues arising from the equipment segment of DOD's Domestic
Preparedness Program and the practical difficulty of implementing
DOD's loan agreements.  Moreover, the many federal WMD consequence
management training, equipment, and response initiatives could
benefit from a coordinated, integrated approach with a defined end
state. 


   RECOMMENDATIONS
----------------------------------------------------------- Letter :10

We recommend that the Secretary of Defense--or the head of any
subsequent lead agency--in consultation with the other five
cooperating agencies in the Domestic Preparedness Program, refocus
the program to more efficiently and economically deliver training to
local communities.  We also recommend that the Secretary, or the head
of any subsequent lead agency, use existing state and local emergency
management response systems or arrangements to select locations and
training structures to deliver courses and consider the geographical
proximity of program cities. 

We recommend that the National Coordinator for Security,
Infrastructure Protection and Counter-Terrorism actively review and
guide the growing number of WMD consequence management training and
equipment programs and response elements to ensure that agencies'
separate efforts leverage existing state and local emergency
management systems and are coordinated, unduplicated, and focused
toward achieving a clearly defined end state. 


   MATTER FOR CONGRESSIONAL
   CONSIDERATION
----------------------------------------------------------- Letter :11

Congress may wish to amend the Nunn-Lugar-Domenici legislation to
provide DOD or any subsequent lead agency greater flexibility in the
conditions under which it provides the $300,000 worth of equipment to
local jurisdictions.  That is, the legislation could be amended to
allow DOD or any subsequent lead agency to provide equipment to local
jurisdictions on such terms and under conditions that it deems
appropriate. 


   AGENCY COMMENTS AND OUR
   EVALUATION
----------------------------------------------------------- Letter :12

DOD, the Departments of Justice and Health and Human Services, and
FEMA provided written comments on a draft of this report.  DOD did
not agree with our recommendation to refocus the Domestic
Preparedness Program or that Congress should consider amending the
program's legislation to allow greater flexibility on the provision
of equipment to local jurisdictions.  It also provided specific
comments on our findings related to threat and risk assessments. 
Justice generally agreed with the substance of our report but did not
comment specifically on our recommendation to refocus the program. 
FEMA noted that our report provided an in-depth examination of the
program.  Health and Human Services and FEMA provided technical
comments, which we incorporated as appropriate.  The comments of
these four agencies and our evaluation of them appear in appendixes
VI to IX.  We also provided a draft of this report to the Department
of Energy, the Environmental Protection Agency, and the National
Security Council, and they did not provide comments. 

DOD stated that we suggest a regional approach to domestic
preparedness but that such an approach is not efficient because the
command and control structure is more difficult to define and is less
able to control first responder training resources within
multi-entity jurisdictions.  DOD also stated that it is better to
have redundant coverage than to wait until regional first responders
can reach the scene of the incident--the bureaucratic process at the
city level is such that each city would likely exhaust its integral
resources before calling on regional actors for support. 

Our report discusses gains in efficiency and effectiveness in
delivering training that could occur if DOD or a succeeding lead
agency were to take advantage of and reinforce the existing emergency
response and training structures at the local and state levels.  Our
evaluation showed that local jurisdictions, states, and federal
agencies are already linked through long-standing emergency response
plans and structures with defined command and control systems.  A
number of localities respond to, or receive back-up support for,
emergencies through well-established county or regional response
structures and through mutual aid arrangements.  Under a more
consolidated approach to the training, emergency response personnel
from nearby cities who might be called upon to assist one another
could receive program training together in one location rather than
in separate training sessions. 

Further, DOD stated that critical to the goal of helping
municipalities establish their own emergency response programs is the
ability to interface with a single entity authorized to direct
appropriate and competent first responder trainers to attend the
instruction.  Regarding DOD's goal of helping municipalities
establish their own emergency response programs, we note that the
legislation authorized support to improve state and local emergency
response agencies' capabilities and did not mandate that
municipalities receive assistance to establish their own emergency
response programs.  Regarding the selection of training participants,
a consolidated approach to delivering training would not prevent
participating jurisdictions from selecting appropriate and competent
personnel to attend the training sessions.  Conversely, DOD's
city-by-city approach does not guarantee that the most appropriate
personnel receive the DOD training.  Some program cities we visited
filled their training slots on the basis of who was available rather
than the training qualifications of participants. 

DOD also commented that redesigning the program would negatively
impact cities' readiness because cities scheduled to receive training
in fiscal year 1999 have already begun to prepare.  We do not believe
that refocusing the program to use existing emergency response and
training structures or to train nearby cities together would
materially delay program completion or harm cities' readiness. 
First, the cities we visited did not spend lengthy periods in advance
of the training to identify training venues or participants.  Second,
under the approach we recommend, nearby program cities currently in
clusters could receive training earlier, if appropriate.  The
efficiencies gained should compensate for any time spent to
reconfigure the program.  This approach should enhance readiness. 
Also, if existing state emergency management training structures were
used, the training could be institutionalized statewide and ensure
the training is sustained over the longer term. 

DOD noted that conducting threat and risk assessments would
negatively affect cities' readiness.  However, as discussed in our
April 1998 report, it would take only about 2 weeks per city to
conduct a threat and risk assessment and determine a prudent and
affordable level of response capability.  DOD further said that
sufficient data is not available to conduct threat and risk
assessments, there is no credible pre-attack predictor, and the FBI
has not identified a specific WMD threat.  As discussed in our April
1998 report, perfect intelligence data or pre-attack predictors are
not needed to perform a sound qualitative threat and risk assessment,
although threat information would be one factor to consider.  Our
prior report showed that a multidisciplinary risk assessment team
would use the best available intelligence information to generate
valid scenarios to perform the risk assessment process. 

DOD also stated that the threat and risk methodology described in the
report is intended for point targets with controlled perimeters and
internal traffic, not for area targets such as cities with virtually
no control over entry, exit, or internal traffic.  The model
highlighted in our April 1998 report has diverse applications and is
not limited to point defense applications.  Additionally, the
President's Commission on Critical Infrastructure Protection
recommended that threat and risk assessments be performed on such
nonpoint targets as the telecommunications and banking and finance
infrastructures.  A rational, businesslike, collaborative assessment
by city, state, and federal representatives can help determine the
appropriate minimum requirements for preparedness, given the threats,
risks, and vulnerabilities for that city.  In our view, such
assessments are conducive to preparedness and awareness.  Assessments
can enhance preparedness by helping decisionmakers prioritize and
target investments of federal and local resources.  Moreover, in
nearly every city we visited, local officials told us they would
welcome such an assessment because they currently have no sound basis
for determining their requirements. 

DOD stated that it does not recommend that Congress amend the
Nunn-Lugar-Domenici legislation to provide greater flexibility for
providing equipment to local jurisdictions as it intends to transfer
the program lead to another agency--the Department of Justice--as
soon as possible.  As stated in our report, DOD's equipment loan
agreement terms have caused frustration and confusion among local
officials.  As a practical matter, because the loan agreement terms
are not likely to be fully implemented, we question the benefits of
using this type of instrument for providing equipment.  Regardless of
which agency leads the program to completion, the program would
benefit from a more practical, less confusing arrangement for
providing equipment to local jurisdictions. 


   SCOPE AND METHODOLOGY
----------------------------------------------------------- Letter :13

We reviewed the Nunn-Lugar-Domenici legislation to determine the
Domestic Preparedness Program's objectives, and we discussed program
design, coordination, and implementation with--and obtained documents
from--several Department of Defense organizations, including the
Assistant Secretary of Defense for Special Operations and
Low-Intensity Conflict, the U.S.  Army Director of Military Support,
and the U.S.  Army Chemical and Biological Defense Command.  We
discussed the same topics with headquarters and many regional
officials of the Federal Emergency Management Agency, the Federal
Bureau of Investigation, the Public Health Service, the Environmental
Protection Agency, and the Department of Energy and also with the
International Association of Fire Chiefs, the International
Association of Fire Fighters, the National Volunteer Fire Council,
and the International Association of Chiefs of Police. 

We interviewed and obtained documents regarding the Domestic
Preparedness Program, including MMSTs, from local officials of
emergency management agencies, fire departments, law enforcement
agencies, and health departments in New York, New York; Los Angeles,
California; Denver, Colorado; Seattle, Washington; Honolulu, Hawaii;
Columbus, Ohio; and Washington, D.C.  We also interviewed state
emergency management officials for most of these locations and
obtained information on their organizations for emergency planning
and response.  We observed domestic preparedness training and
examined equipment in Philadelphia, Pennsylvania, and discussed MMSTs
with the Arlington County, Virginia, fire department.  We discussed
related initiatives with the Department of Justice. 

We analyzed Domestic Preparedness Program city clusters based on city
center to city center mileage calculations, and we based our analysis
of population coverage on 1990 census data, revised in 1994-95.  We
also obtained information on and examined and analyzed, in the
context of program city clusters, state and local emergency response
and training systems and structures in California, Colorado, the
District of Columbia, Hawaii, Ohio, Texas, Virginia, and Washington. 
We did not analyze and compare the content of program training
courses with other agencies' terrorism-related courses to evaluate
the extent of commonality, nor did we fully evaluate other program
initiatives to assist cities by providing equipment or training. 
While we obtained information about PHS' MMST program, we did not
evaluate its implementation. 

We conducted our work from October 1997 to August 1998 in accordance
with generally accepted government auditing standards. 


--------------------------------------------------------- Letter :13.1

As agreed with your offices, unless you publicly announce the
contents of this report earlier, we plan no further distribution of
this report until
5 days after its issue date.  At that time we will send copies to the
appropriate congressional committees; the Secretaries of Defense,
Energy, Health and Human Services, and Justice; the Administrator of
the Environmental Protection Agency; and the Directors of the Federal
Emergency Management Agency and the Office of Management and Budget. 
We will make copies available to other interested parties upon
request. 

If you have any questions about this report, please contact me at
(202) 512-3504.  Major contributors to this report were Davi M. 
D'Agostino, Richard A.  McGeary, Marc J.  Schwartz, and Madelon B. 
Savaides. 

Richard Davis
Director, National Security
 Analysis


DOD DOMESTIC PREPAREDNESS PROGRAM
COSTS, BY FISCAL YEAR
=========================================================== Appendix I

                         (Dollars in millions)

Program category    1997 actual      1998 projected    1999 estimated
----------------  ----------------  ----------------  ----------------
Emergency
 response
 preparedness
Assessment,             $9.5              $7.9              $8.6
 training
 development,
 training
Hot line, help          2.8               3.8               3.2
 line, database
Technical               0.2               0.4               0.5
 support
Equipment               0.9               1.9               1.2
 testing
Equipment               5.1               12.1              11.0
Exercises and
 preparedness
 testing
Training                1.4               4.4               4.4
 exercises
Response                4.0               3.7               9.2
 improvement,
 testing, and
 exercise
Major exercise          2.4               1.5               1.5
Chemical/
 biological
 response
C/B-RRT\a               1.0               0.8               0.8
 support
C/B-RRT\a               5.5               2.0               5.1
 equipment
Training                0.0               0.2               0.2
Program                 3.2               4.5               4.1
 management
======================================================================
Total                  $36.0             $43.1             $49.8
----------------------------------------------------------------------
\a Chemical/Biological Rapid Response Team. 

Source:  Office of the Assistant Secretary of Defense for Special
Operations and Low-Intensity Conflict. 


DOD CONTRACTOR COSTS, FISCAL YEAR
1997
========================================================== Appendix II

                              Percentage
                      Fiscal   of fiscal
                   year 1997   year 1997
Contractor           award\a       total      Main purposes
----------------  ----------  ----------  --  ----------------------------------
Booz-Allen &      $12,554,50        59.7      Equipment packages, training
 Hamilton                  0                   support and preparation, program
                                               management integration and
                                               support, hot line concept, help
                                               line, web page, database
Response           2,769,300        13.2      Exercise support
 Planning, Inc.
Science            1,495,300         7.1      Medical training support
 Applications
 International
 Corporation
Battelle           1,404,700         6.7      Technical and program support,
                                               training assessment
Sonalyst             833,100         4.0      Training videos
Innovative           799,000         3.8      Hot line setup, operations, and
 Emergency                                     equipment database
 Management
EA Procurement       485,200         2.3      Personal protection equipment for
                                               testing
GEO Centers          298,100         1.4      Response communications study
Others (4)           374,500         1.8      Hardware, storage containers
================================================================================
Total             $21,013,70       100.0      Program management, expert
                           0                   assistance, training, exercises,
                                               chemical/biological response
--------------------------------------------------------------------------------
\a Includes subcontractor costs.  For example, EAI Corporation is a
subcontractor of Booz-Allen & Hamilton for equipment packages. 

Source:  U.S.  Army Chemical and Biological Defense Command. 


DOD CONTRACTOR COSTS, FISCAL YEAR
1998
========================================================= Appendix III

                              Percentage of
                Fiscal year    fiscal year
Contractor     1998 award\a    1998 total        Examples of purposes
-------------  -------------  -------------  --  -------------------------------
Booz-Allen &    $16,811,850       58.0           Equipment packages, training
 Hamilton                                         support, program management,
                                                  help line, database, workshops
Response         5,817,683        20.1           Exercise support, response
 Planning                                         improvement support
 Inc.
Science          2,992,148        10.3           Medical training support
 Applications
 Internationa
 l
 Corporation
Battelle         1,069,708         3.7           Response improvement support,
                                                  training assessment
Innovative        999,948          3.4           Hot line operation
 Emergency
 Management
GEO Centers       521,757          1.8           Equipment testing, response
                                                  improvement support, rapid
                                                  response team support
SoBran            335,000          1.2           Multimedia development
Others (4)\b      442,849          1.5           Information technology, cell
                                                  phones, assessment, support
================================================================================
Total           $28,990,943       100.0          Program management, expert
                                                  assistance, training,
                                                  exercises, chemical/
                                                  biological response
--------------------------------------------------------------------------------
Note:  Projected contractor costs for fiscal year 1999 total
$29,796,551, but contractors have not yet been selected.  Costs are
expected to include equipment packages for cities, training support,
hot line operation, exercises, multimedia development, and program
management. 

\a Includes subcontractor costs.  For example, EAI Corporation is a
subcontractor of Booz-Allen & Hamilton for equipment packages. 

\b Also includes contractors who provided materials for equipment
testing. 

Source:  U.S.  Army Chemical and Biological Defense Command. 


DOD EQUIPMENT CATEGORIES AND
SUGGESTED ITEMS
========================================================== Appendix IV

PERSONAL PROTECTION

Fully encapsulated chemical suits with boots and gloves (level A
maximum protection)
Chemical suits with boots and gloves (level B medium protection)
Self-contained breathing apparatus
Disposable decontamination suits

DETECTION

M256A1 chemical agent detector kit
Chemical warfare agent detector kit and tubes
Improved chemical agent detector

DECONTAMINATION

Portable shower kits
Emergency shelter
Sample collection equipment kits

TRAINING AIDS

M256A1 training detector kit
M28 simulator detector tickets
M29 simulator detector tickets
Biological detection tickets
M18A2 chemical detector kit
M8 chemical agent detector paper
M9 chemical agent detector paper
Chemical warfare agent detector kit and tubes
Mark I auto injector trainers
Chemical agent monitor simulator
Reference materials
Course materials


METROPOLITAN MEDICAL STRIKE TEAM
EQUIPMENT CATEGORIES
=========================================================== Appendix V

Personal protection (level A maximum protection for entry into
contaminated zone and level C protection for decontamination
operations)

Detection

Decontamination

Communications

Ancillary equipment

Antidotes and pharmaceuticals for 1,000 casualties




(See figure in printed edition.)Appendix VI
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
=========================================================== Appendix V

those in the report text appear at the end of this appendix. 



(See figure in printed edition.)



(See figure in printed edition.)


The following is GAO's comment on the Department of Defense's (DOD)
letter dated October 2, 1998. 

GAO COMMENT

1.  We modified the text to reflect DOD's comments, as appropriate. 




(See figure in printed edition.)Appendix VII
COMMENTS FROM THE DEPARTMENT OF
JUSTICE
=========================================================== Appendix V




(See figure in printed edition.)Appendix VIII
COMMENTS FROM THE DEPARTMENT OF
HEALTH AND HUMAN SERVICES
=========================================================== Appendix V



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on the Department of Health and
Human Services' letter dated September 22, 1998. 

GAO COMMENTS

1.  We disagree that the lack of valid intelligence depicting an
actual threat prevents a threat and risk assessment.  The threat and
risk process requires assumptions regarding a number of inputs and is
not dependent on definitive intelligence on terrorists. 

2.  This comment pertains to a matter discussed in the draft report
that is not included in the final report. 

3.  We acknowledge in the report that the Department seeks to develop
health systems through the Metropolitan Medical Strike Team (MMST)
program, but there is also an equipment segment of the program that
overlaps with the equipment segment of the DOD Domestic Preparedness
Program.  The fact that the Nunn-Lugar-Domenici initiative contains
two separate, unintegrated, federally funded equipment components has
caused confusion and placed the full burden of coordination on local
agencies. 

4.  We agree that federal agencies should work with locally developed
response structures and believe the report is consistent with this
comment. 

5.  Our report suggests that efficiencies can be gained by using and
reinforcing existing response structures for domestic preparedness
training or by otherwise consolidating training for nearby cities. 
We believe that federally funded equipment should be allocated as
best fits the state and local response structure.  The report does
not suggest creating new regionalized response systems for a weapons
of mass destruction (WMD) incident. 

6.  Both the DOD and the Health and Human Services portions of the
Nunn-Lugar-Domenici initiative have equipment components.  Reference
to National Medical Response Team equipment in the draft report was
deleted in the final report. 

7.  The report discusses the design and implementation of DOD's
training program.  We did not evaluate the integration of MMSTs into
state and local response structures.  We do note, however, that the
Public Health Service (PHS) plans to replicate MMSTs in all 120
Nunn-Lugar-Domenici program cities, which is not clearly leveraging
state and local emergency response structures. 

8.  We modified the text to reflect the Health and Human Services'
comments, as appropriate. 




(See figure in printed edition.)Appendix IX
COMMENTS FROM THE FEDERAL
EMERGENCY MANAGEMENT AGENCY
=========================================================== Appendix V



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on the Federal Emergency Management
Agency's (FEMA) letter dated September 25, 1998. 

GAO COMMENTS

1.  The legislation did not direct FEMA to establish a telephonic
link.  The Chemical and Biological Defense Command (CBDCOM)
established the hot line.  FEMA established the Rapid Response
Information System. 

2.  Reference to FEMA's National Fire Academy and Emergency
Management Institute is made on page 19.  We did not review in detail
federal training programs other than the Domestic Preparedness
Program. 

3.  We agree that an overarching strategy for consequence management
training, equipment, and response initiatives should be developed
with full consideration of legislative and statutory requirements. 

4.  City and state officials commented on the newly established
communications systems in general.  At the time of our review, they
had a limited understanding of the Rapid Response Information System
and its intended use. 

5.  We modified the text to reflect FEMA's comment, as appropriate. 

6.  We accurately portrayed the intelligence community's assessment
of the WMD threat.  We did not suggest that the domestic preparedness
effort be canceled or substantially delayed. 


RELATED GAO PRODUCTS
============================================================ Chapter 0

Combating Terrorism:  Observations on the Nunn-Lugar-Domenici
Domestic Preparedness Program (GAO/T-NSIAD-99-16, Oct.  2, 1998). 

Combating Terrorism:  Observations on Crosscutting Issues
(GAO/T-NSIAD-98-164, Apr.  23, 1998). 

Combating Terrorism:  Threat and Risk Assessments Can Help Prioritize
and Target Program Investments (GAO/NSIAD-98-74, Apr.  9, 1998). 

Combating Terrorism:  Spending on Governmentwide Programs Requires
Better Management and Coordination (GAO/NSIAD-98-39, Dec.  1, 1997). 

Combating Terrorism:  Efforts to Protect U.S.  Forces in Turkey and
the Middle East (GAO/T-NSIAD-98-44, Oct.  28, 1997). 

Combating Terrorism:  Federal Agencies' Efforts to Implement National
Policy and Strategy (GAO/NSIAD-97-254, Sept.  26, 1997). 

Combating Terrorism:  Status of DOD Efforts to Protect Its Forces
Overseas (GAO/NSIAD-97-207, July 21, 1997). 

Chemical Weapons Stockpile:  Changes Needed in the Management
Structure of Emergency Preparedness Program (GAO/NSIAD-97-91, June
11, 1997). 

State Department:  Efforts to Reduce Visa Fraud (GAO/T-NSIAD-97-167,
May 20, 1997). 

Aviation Security:  FAA's Procurement of Explosives Detection Devices
(GAO/RCED-97-111R, May 1, 1997). 

Aviation Security:  Commercially Available Advanced Explosives
Detection Devices (GAO/RCED-97-119R, Apr.  24, 1997). 

Terrorism and Drug Trafficking:  Responsibilities for Developing
Explosives and Narcotics Detection Technologies (GAO/NSIAD-97-95,
Apr.  15, 1997). 

Federal Law Enforcement:  Investigative Authority and Personnel at 13
Agencies (GAO/GGD-96-154, Sept.  30, 1996). 

Aviation Security:  Urgent Issues Need to Be Addressed
(GAO/T-RCED/NSIAD-96-151, Sept.  11, 1996). 

Terrorism and Drug Trafficking:  Technologies for Detecting
Explosives and Narcotics (GAO/NSIAD/RCED-96-252, Sept.  4, 1996). 

Aviation Security:  Immediate Action Needed to Improve Security
(GAO/T-RCED/NSIAD-96-237, Aug.  1, 1996). 

Passports and Visas:  Status of Efforts to Reduce Fraud
(GAO/NSIAD-96-99, May 9, 1996). 

Terrorism and Drug Trafficking:  Threats and Roles of Explosives and
Narcotics Detection Technology (GAO/NSIAD/RCED-96-76BR, Mar.  27,
1996). 

Nuclear Nonproliferation:  Status of U.S.  Efforts to Improve Nuclear
Material Controls in Newly Independent States (GAO/NSIAD/RCED-96-89,
Mar.  8, 1996). 

Aviation Security:  Additional Actions Needed to Meet Domestic and
International Challenges (GAO/RCED-94-38, Jan.  27, 1994). 


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