and vehicles, would require military airlift, like C-130 aircraft. However, there are no plans to dedicate ground crews, flight crews, or aircraft for on-call, immediate response to a RAID team deployment. If Air National Guard or Air Force aircraft were required to transport the RAID teams, authorization would have to be obtained from the U.S. Transportation Command.

The lack of dedicated airlift for the RAID teams adds to the concern about the delayed arrival. Some federal assets, including the FBI's Hazardous Materials Response Unit, have immediate access to aircraft and flight crews. The EPA and Coast Guard On-Scene Coordinators have the ability to contract for civilian aircraft to get their assets, as well as contractor assets, to a scene quickly.

Each RAID team is to be staffed with 22 full-time National Guard members organized into 6 functions: command, operations, administration and logistics, communication, medical, and survey. (See app. II for an organization and staffing chart.) Members are to be on call 24 hours a day, 365 days a year. All but the survey function have a primary mission of RAID team support. For example, the medical unit provides medical support to RAID personnel, as well as guidance to the incident commander on the medical implications of a WMD event and coordination with health care facilities for follow-on support requirements. Each function will have personnel trained to perform their particular mission. The two survey units have the mission of conducting search, survey, surveillance, and sampling of a WMD incident site and advising the incident commander of appropriate response protocols. The survey units are to be capable of working in the "hot zone" at the highest HAZMAT level of entry. Members are to be cross-trained so that a full unit can be fielded at any one time.

All of the HAZMAT team leaders discussed the need to have sufficient team members cross trained in each position to be able to field a complete team when an emergency arises. For example, the Army's Technical Escort Unit; the FBI's Hazardous Materials Response Unit; and the Fairfax County, Virginia, HAZMAT team have sufficient personnel to field multiple units. This allows the units to rotate between on duty, off duty, and training status. If members from the unit on duty are unable to make their shift, the unit leader can call on an equivalent replacement from training or off duty to fill the void. This process also alleviates the concern of having the entire team on call 24 hours a day, 365 days a year, which could cause significant hardships for the team members as they try to maintain normal lives. The RAID team survey function is the only part of the team that has multiple

individuals performing the same job. All other members of the RAID team who could not respond to a deployment call would create a loss of capability for the team. Also, the RAID team will have only one set of equipment for both training and deployment, which could make it difficult to both train on the equipment and be operationally ready to deploy.

Conclusions

The FBI and FEMA are the lead federal agencies for WMD crisis management and consequence management, respectively. The National Security Council position of National Coordinator for Security, Infrastructure Protection, and Counter-Terrorism oversees the broad variety of policies and programs related to counterterrorism, preparedness, and consequence management. We believe that the National Coordinator, in conjunction with the lead federal agencies and DOD, should determine whether the National Guard RAID teams are needed. Local, state, and federal officials responsible for implementing emergency response plans have differing views regarding the role for the RAID teams in those plans. The RAID teams have capabilities similar to those found in local, state, and federal emergency response teams. Many of these teams were not considered when the RAID team concept was created, which may have led to an unnecessary duplication of assets. Concerns about recruiting and retention, training, and operational issues may impact the RAID teams in their ability to meet their responsibilities and mission.

Recommendations

We recommend that the National Coordinator for Security, Infrastructure Protection, and Counter-Terrorism, in consultation with the Attorney General, the Director, FEMA, and the Secretary of Defense, reassess the need for the RAID teams in light of the numerous local, state, and federal organizations that can provide similar functions and submit the results of this reassessment to Congress. If the teams are needed, we recommend that the National Coordinator direct a test of the RAID team concept in the initial 10 states to determine how the teams can best fit into coordinated state and federal response plans and whether the teams can effectively perform their functions. If the RAID teams are not needed, we further recommend that they be inactivated.

Matter for
Congressional
Consideration

Agency Comments and
Our Evaluation

Congress may wish to consider restricting the use of appropriated funds for additional RAID teams until the National Coordinator for Security, Infrastructure Protection, and Counter-Terrorism completes the reassessment we have recommended.

DOD and FEMA provided written comments on a draft of this report.
The FBI and other Department of Justice organizations provided oral
comments. DOD stated that some of our findings and recommendations are
useful as it establishes the RAID teams; however, many are not because
much of our information was not current nor was it gathered from
knowledgeable sources. FEMA and the FBI are the two lead federal
agencies for WMD management. FEMA concurred with the thrust of the
report and its recommendations. The Department of Justice, including the
FBI, concurred with the substance of the report. Comments by DOD and
FEMA are included as appendix III and IV, respectively. We also provided a
draft of this report to the National Security Council, which did not provide
comments. We revised the report to reflect technical comments provided
by DOD, FEMA, Department of Justice, and other organizations, as
appropriate.

FEMA stated that the report makes three important points. First, and foremost, for an incident of chemical terrorism, local responders—not a National Guard or federal team that arrives hours later-will perform the most immediate life-saving response tasks. Second, there are federal assets that can assist state and local officials with follow-on response tasks for chemical terrorism. New chemical capabilities for the Guard may not be necessary to support federal operations. Third, apparently there also is a difference of opinion among states regarding the need for new National Guard teams to support state operations.

DOD stated that many of our findings are not useful because they are based on data, opinions, and analysis that preceded the October 17, 1998, congressional direction to create 10 RAID teams. DOD also said that our report and the views expressed therein are based on the Department's plans, not on its implementation of the RAID team concept. Moreover, it stated that the report takes into account only a select portion of DOD's capacity to respond to terrorist use of WMD on domestic targets and makes reference to interviews with both civilian and military responders who have neither the knowledge of the DOD program nor of the ongoing coordination between DOD and other organizations. Also, DOD said that

several states have submitted a request for or expressed interest in fielding their own RAID teams, including Virginia and Utah. In commenting on our first recommendation, DOD said that the FBI, FEMA, the National Security Council, and the Office of Management and Budget had reviewed and concurred with its plan to create the RAID teams. DOD said that it is already implementing our second recommendation, which calls for a test of the RAID concept in the first 10 states. DOD's position on the third recommendation is that the RAID teams are needed and should not be inactivated.

With respect to the scope of our work, we conducted our review through March 1999 and included the most up-to-date information available at that time. We reviewed DOD's plans for the RAID teams and the implementation of those plans. For example, we discussed Pennsylvania's progress in fielding its RAID team and incorporating the team's capabilities into the state's WMD response plan. Although DOD states that the RAID teams were created by congressional direction on October 17, 1998, the teams were a DOD initiative and Congress, in passing the fiscal year 1999 Defense Appropriations Act on that date, funded DOD's initiative. Our focus was on the RAID teams and not DOD's total capacity to respond to WMD incidents. We assessed the teams against their stated roles and responsibilities, not against DOD's total support requirements. Therefore, we believe our assessment is valid. While we agree that the FBI, FEMA, the National Security Council, and the Office of Management and Budget reviewed the plans for the RAID teams, our discussions with officials from the FBI and FEMA and these agencies' comments on our report show that differing views continue to exist.

With respect to DOD's list of states requesting RAID teams, it is reasonable to expect that many states might express an interest in receiving a trained and equipped RAID team that could respond both to WMD events and HAZMAT emergencies since its cost would be borne by the federal government. The officials with whom we discussed the RAID teams' roles and responsibilities were recommended by their federal agencies or state and local entities as being most knowledgeable of WMD response plans and the implementation of those plans. All of these were aware of the RAID team concept, most had been briefed on the concept, and many had provided comments to DOD on it.

We continue to believe that our recommendations are valid and that the need for the RAID teams should be reassessed. We do not believe that the RAID teams were created based on careful consideration of

governmentwide priorities, an analysis of the program in relation to those priorities, and an allocation of resources based on priorities and an analytical assessment of the threat and risk of a WMD attack. A reassessment at this juncture is important because DOD has requested funds for five additional RAID teams in the fiscal year 2000 budget request. If it is determined that the RAID teams are needed, as DOD states in its comments, we believe it is premature to expand the RAID concept beyond the original 10 locations until it is determined how the teams can best fit into coordinated state and federal response plans, and whether the teams can effectively perform their functions. In light of differing views among DOD, FEMA, and the FBI regarding whether a reassessment of the RAID teams is needed and the fact that the National Coordinator did not provide comments on our report, Congress may wish to consider restricting the use of appropriated funds for any additional RAID teams until the reassessment we recommended is complete. Accordingly, we have included a matter for congressional consideration in our report.

Scope and
Methodology

To determine what federal entities have capabilities similar to the RAID teams, we interviewed officials and reviewed documents from the FBI; FEMA; EPA; U.S. Coast Guard; U.S. Army Soldier and Biological Chemical Command; U.S. Air National Guard; U.S. Army 15th Support Brigade; and U.S. Army Reserve. To determine what local and state assets have similar capabilities, we interviewed officials from Fairfax County, Virginia; Montgomery County, Maryland; Chicago, Illinois; and the states of Utah, Virginia, and Pennsylvania. We also reviewed documents from Utah, Virginia, and Pennsylvania. These locations were selected to provide a range of perspectives, which includes states with and without a RAID team, states with major population centers and with more rural areas, and states with robust HAZMAT capabilities at the state level and those with less capability.

To determine how the RAID teams would be integrated into local, state, and federal response plans, we interviewed officials and reviewed documents from the FBI; FEMA; U.S. Army 15th Support Brigade; Fairfax County, Virginia; Montgomery County, Maryland; Chicago, Illinois; the states of Utah, Virginia, and Pennsylvania; and the International Association of Fire Chiefs.

We reviewed the Department of Defense Plan for Integrating National
Guard and Reserve Component Support for Response to Attacks Using
Weapons of Mass Destruction to determine how the concept of the RAID