GAO

United States General Accounting Office

Report to Congressional Requesters

May 1999 COMBATING 

TERRORISM

Use of National Guard 

Response Teams 

Is Unclear

GAO/NSIAD-99-110

Page 1 GAO/NSIAD-99-110 Combating Terrorism

United States General Accounting Office

Washington, D.C. 20548 Letr

National Security and

International Affairs Division

B-282299 Letter

May 21, 1999

The Honorable Christopher Shays

Chairman, Subcommittee on National Security,

Veterans’ Affairs, and International Relations

Committee on Government Reform

House of Representatives

The Honorable Ike Skelton

Ranking Minority Member

Committee on Armed Services

House of Representatives

The Honorable Bob Barr

House of Representatives

In September 1997, we reported that many federal agencies had duplicative 

or overlapping capabilities and missions in combating acts of terrorism,1

including incidents involving the use of weapons of mass destruction 

(WMD).2

 Recently, the Department of Defense (DOD) approved the 

creation of 10 National Guard Rapid Assessment and Initial Detection 

(RAID) teams to assist local and state authorities in assessing the situation 

surrounding a WMD emergency; advise these authorities regarding 

appropriate actions; and facilitate requests for assistance to expedite the 

arrival of additional state and federal military assets. As requested, we 

(1) obtained the views of federal, state, and local officials regarding the role 

of RAID teams in response plans; (2) determined whether there are other 

federal, state, or local government entities that can perform similar 

functions to the RAID teams; and (3) evaluated the RAID teams’ roles and 

responsibilities and how the teams plan to meet these responsibilities.

1Combating Terrorism: Federal Agencies’ Efforts to Implement National Policy and Strategy

(GAO/NSIAD-97-254, Sept. 26, 1997).

2

For purposes of this report, WMD are defined as biological, chemical, or radiological weapons.

Letr
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Results in Brief We have previously reported that the many and increasing number of 

participants and programs in the evolving terrorism area across the federal 

government pose a difficult management and coordination challenge to 

avoid program duplication, fragmentation, and gaps. While DOD has 

defined the specific mission for the RAID teams, the plans for the teams 

and their implementation continue to evolve. We found that there are 

differing views on the role and use of the RAID teams and how they will fit 

into state and federal plans to respond to weapons of mass destruction. 

Army officials believe the teams can be a valuable asset to federal 

authorities, if needed, as part of the federal response plan. They also 

believe that the teams will be a critical and integral part of the state and 

local response to such weapons. Officials with the two agencies 

responsible for managing the federal response to terrorist incidents—the 

Federal Bureau of Investigation and the Federal Emergency Management 

Agency—do not see a role for the RAID teams in the federal response. 

Instead, they see the National Guard, whether in state or federal status, 

providing its traditional assistance in emergencies. Differing views also 

exist at the state level. Officials in states without a RAID team do not see 

how the teams can benefit their states’ response capabilities because of the 

time it takes the RAID teams to respond. However, one state official does 

see the RAID team bringing some expertise that could be useful. Officials in 

Pennsylvania, a state with a RAID team, plan not only to fully integrate its 

team into the state’s weapons of mass destruction response plan, but also 

use it to respond to more common hazardous materials emergencies.

There are numerous local, state, and federal organizations that can perform 

similar functions to the RAID teams. For example, there are over 600 local 

and state hazardous materials teams in the United States that daily have to 

assess and take appropriate actions in incidents involving highly toxic 

industrial chemicals and other hazardous materials. In addition, there are 

numerous military and federal civilian organizations that can help local 

incident commanders deal with weapons of mass destruction incidents by 

providing advice, technical experts, and equipment.

Our discussions with local, state, and federal officials and our analysis 

surfaced a number of concerns that could impact the teams’ abilities to 

meet their mission and responsibilities. These concerns centered on 

recruiting and retention, training, and operational issues.

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These issues further point to the need for a more focused and coordinated 

approach to the U.S. response to attacks involving weapons of mass 

destruction—an approach that capitalizes on existing capabilities, 

minimizes unnecessary duplication of activities and programs, and focuses 

funding on the highest priority requirements. Because of the differing views 

on the role and use of the RAID teams, the numerous organizations that can 

perform similar functions, and the potential operational issues that could 

impact the teams, we are recommending that the appropriate federal 

agencies determine the need for the teams. If it is determined that the 

teams are needed, we further recommend that the RAID team concept be 

tested to determine how the teams can effectively perform their functions. 

If they are not needed, we recommend that they be inactivated. In light of 

differing views regarding a reassessment of the need for the RAID teams, 

Congress may wish to consider restricting the use of appropriated funds for 

any additional teams until the reassessment we recommended is complete. 

We have included a matter for congressional consideration in this report.

Background Operationally, federal efforts to combat terrorism are organized along a 

lead agency concept. The Department of Justice, through the Federal 

Bureau of Investigation (FBI), is responsible for crisis management of 

domestic terrorist incidents and for pursuing, arresting, and prosecuting 

the terrorists. State governments have primary responsibility for managing 

the consequences of domestic disasters, including major terrorist 

incidents; however, the federal government can support state and local 

authorities if they lack the capabilities to respond adequately. The Federal 

Emergency Management Agency (FEMA) manages this federal support 

through a generic disaster contingency plan known as the Federal 

Response Plan, which outlines the roles, responsibilities, and emergency 

support functions of various federal agencies, including DOD, for 

consequence management. The National Security Council’s National 

Coordinator for Security, Infrastructure Protection, and Counter-Terrorism, 

created in May 1998 by Presidential Decision Directive 62, oversees the 

broad variety of relevant policies and programs, including such areas as 

counter-terrorism, preparedness, and consequence management for WMD.

According to intelligence agencies, conventional explosives and firearms 

continue to be the weapons of choice for terrorists. Many familiar with 

industrial chemicals, such as officials from the FBI, the Environmental 

Protection Agency (EPA), the Coast Guard, and local hazardous materials 

(HAZMAT) teams, believe that industrial chemicals may also be a weapon 

of choice in terrorist attacks because they can be easily obtained and 
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dispersed. Terrorists are less likely to use chemical and biological weapons 

than conventional explosives, at least partly because these materials are 

more difficult to weaponize and the results are unpredictable. Agency 

officials have noted that terrorists’ use of nuclear weapons is the least 

likely scenario, although the consequences could be disastrous. According 

to the FBI, the threat from chemical and biological weapons is low, but 

some groups and individuals of concern are beginning to show interest in 

such weapons.

Our September 1997 report stated that more than 40 federal departments, 

agencies, and bureaus have some role in combating terrorism and that 

many of these organizations have duplicative or overlapping capabilities 

and missions. In a December 1997 report3

 and an April 1998 testimony,4 we 

reported that the many and increasing number of participants and 

programs in the terrorism area across the federal government pose a 

difficult management and coordination challenge to avoid program 

duplication, fragmentation, and gaps. We also discussed the need for threat 

and risk assessments to help the government make decisions about how to 

target investments and set priorities for combating terrorism. 5

 We 

recommended that the National Security Council’s National Coordinator 

for Security, Infrastructure Protection, and Counter-Terrorism, review and 

guide the growing number of federal terrorism 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.

In November 1997, the Deputy Secretary of Defense directed that DOD 

develop a plan to integrate the National Guard and Reserves into the DOD 

response to WMD attacks. The result was the Department of Defense Plan 

for Integrating National Guard and Reserve Component Support for 

Response to Attacks Using Weapons of Mass Destruction, issued January 

1998. It outlined the capabilities the U.S. military might be called on to 

provide in support of civil authorities during a WMD attack, the capabilities 

3

Combating Terrorism: Spending on Government-wide Programs Requires Better Management and 

Coordination (GAO/NSIAD-98-39, Dec. 1, 1997).

4Combating Terrorism: Observations on Crosscutting Issues (GAO/T-NSIAD-98-164, Apr. 23, 1998).

5

A threat and risk assessment would begin by identifying and evaluating each threat on the basis of 

various factors, such as its capability and intent to attack an asset, the likelihood of a successful attack, 

and its lethality. This information would be part of a deliberate process of understanding the risk, or 

likelihood, that a threat will harm an asset with some severity of consequences.
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that existed in the military, and the gaps in DOD’s capability to respond. 

The plan led to the creation of the RAID teams. 

According to Army National Guard officials, the RAID team concept is a 

Secretary of Defense initiative. The Army Guard is responsible for 

implementing the concept and has developed the plans for organizing, 

staffing, training, and equipping the teams for their mission. Since this is a 

new concept, the plans and their implementation continue to evolve. 

Funding for the teams will be through the Army Guard and includes 

personnel costs for the full-time positions, as well as training, equipment, 

and maintenance costs. DOD allocated about $19.9 million from the fiscal 

year 1999 Defense Appropriations Act for the first year of the program, 

which covered the startup costs for the first 10 teams. An omnibus 

supplemental appropriation followed, from which DOD allocated an 

additional $19.2 million for RAID team equipment and $13 million to 

establish RAID (Light) teams in states that do not have a full RAID team. 

The DOD budget request for fiscal year 2000 includes about $37.2 million to 

support the 10 existing RAID teams and create 5 more. It also includes 

about $0.5 million to support the RAID (Light) teams.

According to Army officials, the Secretary of Defense plans that the RAID 

teams will be dedicated forces for domestic incidents. The initial 10 teams 

are located in Washington, California, Colorado, Texas, Illinois, Missouri, 

Georgia, Pennsylvania, New York, and Massachusetts. Each of these states 

is within a defined FEMA region and was selected based on demographics 

of the state, proximity to Air National Guard units that could provide airlift, 

presence of other federal/military assets, transportation networks, and 

other criteria. (See app. I for a map showing the FEMA regions and the 

RAID team locations.) Consideration was also given to the level of 

congressional interest in the locations of the teams. State National Guard 

organizations receiving the teams have started hiring and training 

personnel in their individual skills. The 10 RAID teams are scheduled to be 

operational in January 2000. Currently, the team is an asset of the state in 

which it is located, but can be deployed as a regional asset to other states. 

The DOD plan suggested that there eventually should be a RAID team in 

each state, territory, and the District of Columbia, for a total of 54 teams. 

Until this occurs, the Army Guard is establishing RAID (Light) teams in the 

other 44 locations to provide limited chemical/biological response 

capabilities. 
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Officials Have Differing 

Views on the Role and 

Use of National Guard 

Raid Teams in 

Response Plans

There are differing views on the role and use of the National Guard RAID 

teams and how they will fit into plans to respond to incidents involving 

WMD. Army officials believe the teams can be a valuable asset to federal 

authorities, if needed, as part of the Federal Response Plan. They also see 

the teams as a critical part of the local and state response to such incidents. 

Federal officials most involved in managing the Federal Response Plan 

during a WMD incident did not see a role for the National Guard RAID 

teams. Local and state officials also have differing views. Local officials 

with robust HAZMAT capabilities saw the RAID teams benefiting those 

jurisdictions with lesser HAZMAT capabilities. Officials from states without 

a RAID team do not see the use of the team in their WMD response efforts 

because of the time it takes the RAID team to respond. One state official 

does see the team bringing some useful expertise. Officials from 

Pennsylvania, one of the states to receive a RAID team, plan to fully 

integrate their team into the state’s response plan.

Army Officials See the RAID 

Teams as Critical to WMD 

Response Efforts

The DOD team that worked on the January 1998 plan reviewed the Federal 

Response Plan to determine the emergency support functions and vital 

tasks that DOD would likely be asked to support. The team requested the 

military services to assess their capabilities to perform these tasks and 

consolidated the responses to identify existing gaps in the DOD capability 

to respond to a WMD event. The team also reviewed other DOD-sanctioned 

studies on terrorism and command response plans. In designing the RAID 

teams, Army officials stated they tried to create a capability that would fill 

the greatest shortfall identified in the study—the ability to detect and 

identify WMD. This capability is critical to any effective response effort 

and, according to these officials, was missing from most local and state 

response units. The RAID team focus will be WMD and, as such, the team 

would be subject matter experts, instead of HAZMAT experts with an 

awareness of WMD. According to these officials, having the RAID team in 

the National Guard gives the state governor an asset that can be rapidly 

deployed to provide this initial WMD detection and identification support, 

as well as technical advice on handling WMD incidents, to the local 

incident commander. Also, according to these officials, it is less expensive 

to have one state asset trained and equipped to deploy with this capability 

than to train and equip every HAZMAT team in the state.

According to Army officials, the RAID teams will also provide advantages 

that are not presently available at the local, state, or federal levels. For 

example, the teams will serve as a model for state and local WMD response 
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organizations and will provide both DOD and industry a place to identify 

requirements and test new concepts and equipment in WMD detection and 

identification. The teams will also provide a liaison between the local and 

state responders and the manufacturers of equipment to ensure that the 

responders have knowledge of state-of-the-art equipment to manage WMD 

incidents. According to the officials, the RAID teams will also fill a very 

important force protection role for the National Guard. Once other Guard 

units are deployed to the incident, they will need to know which areas are 

not contaminated so they can carry out their duties safely. The RAID team 

will be able to communicate this information to other Guard units, as well 

as provide advice to the Guard commander regarding operating in a WMD 

environment.

Officials Question Role of 

RAID Teams in Federal 

Response Structure

Officials from the FBI and FEMA are concerned about the RAID team 

concept and how the teams would fit into any federal WMD response. They 

question the need for the RAID teams because of the federal structure 

already available to respond to WMD incidents. The FBI officials are 

concerned about a conflict between the RAID teams and their own 

Hazardous Materials Response Unit or other federal assets, if all arrive with 

the same capabilities and try to give advice to the incident commander. 

FEMA officials are also concerned about the duplication of capabilities 

between the RAID teams and the local and state HAZMAT teams. They can 

see the RAID teams perhaps disrupting the relationship that already exists 

between the local, state, and federal responders. 

Federal, state, and local officials generally agree that a WMD incident 

involving chemical agents would look like a major HAZMAT emergency. In 

such scenarios, the local HAZMAT team would be the first to respond and 

the local fire chief would usually be the incident commander. If the local 

responders are unable to manage the situation or are overwhelmed, the 

protocol is for the incident commander to contact nearby communities and 

the state emergency management office for assistance. The RAID team 

could be requested at that point. However, the local commander also has 

access to federal assets through the National Response System hotline, 

discussed later in this report. According to officials from the International 

Association of Fire Chiefs, the hotline is well publicized and known within 

the first responder community. 

If the incident commander suspects that the event is a WMD incident, a 

similar hotline can be used to get information or assistance. The Domestic 

Preparedness Program directed that the U.S. Army, as executive agent, 
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create this Chemical and Biological Hotline to report suspected or 

confirmed WMD incidents.6

 The Army contracted with the Coast Guard to 

manage this hotline through the same center the National Response System 

uses, which links the caller to both the Army’s Soldier and Biological 

Chemical Command for advice and the FBI to begin the federal response. 

The incident commander can also call the local office of the FBI, which 

would trigger the federal response. According to FBI officials, the local FBI 

offices try to work with local and state emergency responders to plan 

responses for WMD incidents. The RAID teams are not part of the Federal 

Response Plan and would not be notified through the National Response 

System.

The Federal Response Plan provides for a Defense Coordinating Officer, 

who is the single point of contact for Federal Response Plan agencies 

regarding military assistance in a disaster.7

 The Officer is responsible for 

validating those agencies’ requests for military assistance, identifying and 

deploying active and reserve units for the mission, and for operational 

control of the units that are deployed. According to the Defense 

Coordinating Officer we spoke with, the RAID team would duplicate the 

Officers’ role of identifying the units that could provide military assistance 

in a WMD event. The request for assistance would have to be made through 

the Defense Coordinating Officers because they have call up and 

deployment authority for units (other than National Guard units in state 

status) and the RAID teams do not have that authority.

According to Army officials, the RAID team’s WMD focus would be 

invaluable to the Defense Coordinating Officers in their responsibilities 

under the Federal Response Plan, because of the team’s knowledge of 

other military assets with a WMD response capability. The incident 

commander may request assistance for a particular task without knowing 

what military units are available to accomplish the task. According to the 

officials, the RAID team could translate that request into a specific type of 

military unit that would provide the most effective assistance to meet the 

incident commander’s needs and provide the Defense Coordinating Officer 

information regarding the type and locations of that type of unit.

6See our report Combating Terrorism: Opportunities to Improve Domestic Preparedness Program 

Focus and Efficiency (GAO/NSIAD-99-3, Nov. 12, 1998) for a discussion of this program.

7

There are officers assigned to each state, territory, and the District of Columbia.
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Differing Views of the RAID 

Team Role Exist at State 

and Local Levels

Because the RAID teams are just getting established, there is not much 

information about the teams at the state and local levels. Therefore, we 

contacted only a few states, including Pennsylvania, which has a RAID 

team, and local jurisdictions to obtain their opinion on the RAID team 

concept. Most local and state officials we spoke with do not see a role for 

the RAID teams in their response framework. However, officials from 

Pennsylvania, one of the states to receive a RAID team, are enthusiastic 

about the concept. Officials from larger jurisdictions usually have very 

robust HAZMAT capabilities. Many of the officials we spoke with stated 

that they see no use for the RAID teams because their own experienced 

technicians can not only perform sufficient detection and identification to 

begin to handle the situation, but also work in the stressful, dangerous 

environment. They also did not see the RAID team providing advice on 

situation assessment and management, which is another of the RAID team 

missions. These officials consider themselves very experienced in 

managing HAZMAT emergencies and did not believe the RAID team could 

suggest anything they did not already practice every day. However, some of 

the officials did state that perhaps the RAID teams could be a useful asset 

for those locations with little or no HAZMAT capability. One state official 

stated that the RAID team could bring certain capabilities to a WMD event, 

such as expertise on military agents.

Officials from Utah’s Division of Comprehensive Emergency Management 

stated that a RAID team would not respond to a WMD emergency in time to 

be of much help. Since a detachment of the Army’s Technical Escort Unit is 

already stationed in the state and the state emergency management 

officials have a relationship with the Unit, officials believe the RAID team 

capability would not be effective for their state.

An official from the Virginia Department of Emergency Services believes 

the RAID team, as a regional asset, would not arrive in time to be an 

effective response asset, especially since the RAID team would not operate 

routinely with Virginia’s existing coordinated and integrated response 

program. Virginia has 13 HAZMAT response teams that operate as local 

teams until called upon to assist another jurisdiction under the state mutual 

aid agreement. It also has hundreds of highly trained technicians on other 

HAZMAT teams that can perform the basic detection and identification 

tasks that allow them to begin to handle a WMD emergency. The official 

also expressed concern about how the RAID team would interact with the 

HAZMAT teams already on the scene and what they would do to assist if 

they arrived too late to provide the expertise for which they were trained. 
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However, he does believe that the RAID teams could bring certain 

capabilities to a WMD event, such as specific expertise concerning military 

agents, and acting as liaison between the civilian response and the military 

assets brought in to assist. He also believes that a RAID team could add 

materially to Virginia’s preparedness and response capabilities, if it was 

properly trained and equipped and had a well-defined mission consistent 

with and integrated into Virginia’s overall Terrorism Consequence 

Management concept.

The state and federal officials stated that the National Guard, in its 

traditional assist role, would be necessary and invaluable in a WMD 

emergency as in natural disasters and other emergencies. They, as well as 

officials from the International Association of Fire Chiefs, agreed that the 

detection and identification capabilities in the RAID teams would be better 

placed in the local responder community, since the local responders will be 

on the scene first and need information quicker than the RAID team, or any 

federal assets, could get there to provide it. According to some officials, an 

investment in more sophisticated detection and identification equipment 

and advanced training for HAZMAT teams would benefit the teams’ 

response to all HAZMAT emergencies, not just WMD incidents. As we 

discussed in our November 1998 report, the Domestic Preparedness 

Program is providing the largest 120 cities in the United States with the 

opportunity to expand their WMD capabilities; however, there are concerns 

about some aspects of the program.

Pennsylvania State Emergency Management Agency officials are very 

enthusiastic about the concept. Even though there are state certified 

HAZMAT teams in 42 of the 67 counties in the state, the officials are 

modifying their state response plans to include the RAID team as the 

primary state asset to deploy in a WMD chemical emergency. They also 

plan to have the RAID team operate in non-WMD HAZMAT emergencies. 

They believe this not only gives the team a chance to gain operational 

experience and learn to operate as a team in the stressful HAZMAT 

environment, it also gives the state an additional HAZMAT asset to deploy. 

The officials dismissed the idea of relying on federal assets because of 

concerns about their availability and responsiveness if the state ever 

needed them.
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Similar Capabilities 

Exist at Local, State, 

and Federal Levels

The RAID teams are to assist local and state authorities in assessing a WMD 

event; advise these authorities regarding appropriate actions; and facilitate 

requests for assistance to expedite arrival of additional state and federal 

military assets. The January 1998 DOD plan that led to the creation of the 

RAID teams focused on some of the military assets with similar capabilities 

available to support local authorities in a WMD event. It did not consider 

over 600 state and local HAZMAT teams that have to assess and take 

appropriate actions in incidents involving highly toxic industrial chemicals 

and other hazardous materials. Some of these local teams are receiving 

training and equipment through the federal Domestic Preparedness 

Program that will give them the capability to respond to WMD events. The 

plan also did not discuss many of the civilian federal organizations that can 

provide advice or respond with personnel and equipment to help mitigate 

the effects of a WMD. Finally, the plan was developed without the benefit of 

an analytically sound threat and risk assessment. We have said in prior 

reports and testimonies that such assessments can help decisionmakers in 

targeting investments, setting priorities, and minimizing program 

duplication.

Local and State 

Governments Have 

Substantial HAZMAT 

Capabilities

According to local, state, and federal officials, a chemical terrorism event 

will likely look like any major HAZMAT emergency and HAZMAT teams will 

be the first to reach the scene. HAZMAT technicians are trained to detect 

the presence of highly toxic industrial chemicals and can use basic 

identification techniques and equipment to give them sufficient information 

to begin to assess and respond to the situation. For example, the chemical 

agent sarin is from the same organophosphate compound family of 

chemicals as pesticides. HAZMAT technicians can identify this chemical 

family using readily available kits. The technicians are trained and 

experienced in the protocols used to handle this chemical family and can 

begin to mitigate the chemical immediately. The identification of biological 

agents requires a complex process performed in a lab and cannot, as yet, be 

done on scene by any unit, including the RAID teams. However, it is likely 

that detecting and identifying an actual biological agent will involve the 

medical community over a period of days rather than the HAZMAT 

community or the RAID teams over a matter of hours. 

According to the International Association of Fire Chiefs, there are over 

600 local and state HAZMAT teams that will be the first to respond to an 

event involving hazardous materials, whether it is a WMD agent, industrial 

chemical, or other material. Although these teams vary in capability, 
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ranging from basic to robust, they all have the basic capability to detect and 

identify industrial chemicals and mitigate the effects of a chemical 

emergency, either on their own or with help from nearby jurisdictions, 

private contractors, or federal organizations. 

Some areas have small teams with little HAZMAT equipment. For example, 

Utah currently has five Utah Highway Patrol troopers trained to the level of 

HAZMAT technician who are responsible for managing hazardous material 

emergencies throughout the state. They have basic chemical identification 

kits and laptop computers in their patrol cars that allow them to identify 

the family of chemicals they are faced with and provide information on 

how to mitigate the effects. Beyond the troopers, the state relies on a 

network of amateur radio operators, city HAZMAT teams, volunteers with a 

level of awareness in chemicals, oil company teams, and a detachment of 

the Army’s Technical Escort Unit stationed in the state to handle large 

emergencies. The state is planning to expand its HAZMAT capability with 

enough trained volunteers to staff six regional teams, available on an 

as-needed basis. According to officials from Utah’s Division of 

Comprehensive Emergency Management, this capability, with some 

awareness training for those involved, will be sufficient to begin to manage 

the consequences of a WMD event involving chemical agents. 

Local jurisdictions such as Chicago, Illinois; Fairfax County, Virginia; and 

Montgomery County, Maryland have more robust HAZMAT units. These 

units can handle large HAZMAT situations involving the most toxic 

industrial chemicals with little or no help because of investments in 

equipment, training, and staff. The units have more sophisticated detection 

and identification equipment that allows them to know what chemical is 

present. They are usually outfitted with a higher level of equipment, 

including personal protection suits with self-contained breathing 

mechanisms that allow them to enter the “hot zone” area of most intense 

contamination to quickly begin to manage the situation.

The largest cities in the United States, usually the ones with the more 

robust HAZMAT capabilities, are included in the 120 cities scheduled to 

receive WMD training, assistance, and equipment through the Domestic 

Preparedness Program. In our November 1998 report, we reported that the 

training and equipment that DOD is providing to cities through the program 

have clearly increased cities’ awareness of and should better prepare them 

to deal with a chemical or biological terrorist incident. State, local, and 

federal officials agree that the capability for managing a WMD event should 

be in the hands of the people who will have to deal with the situation first 
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and who most need it—the first responder community. According to these 

officials, it would be far more effective to improve the capabilities in the 

first responder community than to create additional capabilities to assist 

them.

Military Assets Available to 

Assist First Responders

There are 89 Air National Guard civil engineering units spread throughout 

the 50 states, Guam, Puerto Rico, and the District of Columbia, that the 

state governors or federal officials can access to help in a WMD event. 

These civil engineering units—Prime Base Engineering Emergency Forces, 

known as “Prime BEEF” units—have the wartime mission of supporting 

sustained air operations with equipment and personnel to ensure 

capabilities for operating and surviving in a WMD attack and mitigating the 

consequences of an attack. Their functions include monitoring chemical 

plumes, detecting and identifying chemical agents and radioactivity, 

controlling contamination, decontaminating equipment and personnel, 

assessing the situation, and building temporary shelters. The Air Guard also 

has 78 Prime BEEF fire fighting units that are trained in handling hazardous 

materials, such as jet fuel and hydrazine, related to aircraft maintenance 

and operations and cleaning up spills. In addition, the Air Guard has 

10 Explosive Ordnance Disposal units that are capable of handling WMD 

devices and plans to increase the number of these units to 44 in the next 

5 years. According to Air Guard officials, these skilled units could be of 

great use to local incident commanders in a WMD attack on civilian targets, 

if their equipment and training were upgraded to allow “hot zone” entry and 

they trained with the local first responders. This would allow these units to 

be available to the states, not only in a WMD event, but also in a major 

HAZMAT emergency. 

There are highly specialized military assets to deal with the full range of 

WMD. These include the Army’s Technical Escort Unit, with three 

detachments stationed across the United States; the U.S. Marine Corps’ 

Chemical/Biological Incident Response Force stationed at Camp Lejeune, 

North Carolina; the Army’s 52nd Explosive Ordnance Disposal teams, 

stationed across the United States; military laboratories, such as the U.S. 

Army Medical Research Institute of Infectious Diseases; and other assets, 

such as the Mobile Analytical Response System from the Edgewood 

Research, Development and Engineering Center. Many of these units have 

the capability to detect and identify WMD as well as perform other 

WMD-related tasks, such as locate and render safe WMD devices or 

decontaminate victims. Many of these units have been positioned at large 
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events such as the Atlanta Summer Olympic Games, economic summits, 

and presidential inaugurations in case of a terrorist attack. 

The military services, both active and reserve, have units that could be used 

in a WMD emergency. For example, the U.S. Army Reserve has 63 percent 

of the chemical units in the U.S. Army, including 100 chemical 

reconnaissance/decontamination elements stationed across the United 

States that can perform basic detection and identification of chemical 

agents as well as decontamination operations. The U.S. Army Reserve also 

has two chemical companies that are specifically designed for nuclear, 

chemical, and biological reconnaissance. The U.S. Army Reserve contains 

the only biological detection company in the Army today that is ready to 

deploy and also has many soldiers with command and control expertise 

and chemical specialties that can be deployed as individual experts to a 

WMD situation. Under the authority of Army Regulation 500-60, a Reserve 

commander can respond to an emergency in the local area when there is 

imminent danger of loss of life or critical infrastructure. Accordingly, the 

local authorities could request assistance from the local Reserve 

commander in a WMD emergency without an official deployment of the 

military. 

Federal Civilian Assets 

Available to Assist First 

Responders

Some civilian federal agencies have assets that can assist first responders 

in a WMD emergency. This assistance can be in the form of information or 

response teams. The National Response System, which has been in 

operation for over 30 years, provides 24-hour telephone hotline access to 

federal agencies. Although the system is primarily to report emergencies 

involving chemical or oil spills, it could also alert federal authorities to 

what could turn out to be a WMD event. 

EPA is responsible for preparing for and responding to emergencies 

involving oil and hazardous substances, including radiological substances, 

for all natural and manmade incidents, including those caused by terrorism. 

The U.S. Coast Guard is responsible for the same kinds of incidents as they 

impact the U.S. coastal waters. When a local or state responder calls via the 

National Response System for EPA or Coast Guard assistance, the call is 

immediately relayed to either agency’s on-scene coordinator. These 

coordinators have the authority to manage all response efforts at the scene 

of an incident. The EPA has about 270 on-scene coordinators across the 

United States and the Coast Guard has 44 Marine Safety Officers, who are 

coordinators. Most coordinators try to deploy within a half-hour of notice. 

The coordinators have HAZMAT training, can assist with situational 
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assessment, and are the point of contact for the coordination of federal 

HAZMAT efforts with the local and state responders. If the state asks for 

assistance, the coordinator can bring both contractor and federal assets to 

the scene. 

Both EPA and the Coast Guard have other assets that respond to HAZMAT 

emergencies. The EPA has two Environmental Response Teams, stationed 

in New Jersey and Ohio, that can respond to a HAZMAT emergency. These 

teams can bring to the scene analytical and monitoring equipment for 

detecting and identifying materials, including chemical weapons. They also 

have decontamination and risk assessment capability, as well as other 

expertise. The teams have the capability to perform “hot zone” entry 

with the highest level of personal protective equipment. EPA also has 

10 Superfund Technical Assessment and Response Teams, 1 in each EPA 

region, that have similar HAZMAT capabilities and access to contractor 

support.8

 EPA’s National Enforcement Investigations Center is the 

technical support center for EPA enforcement and compliance assurance 

programs, providing environmental forensic evidence collection, sampling, 

and analysis and can also assist the FBI with these activities. EPA has 

12 labs that provide analytical support, field monitoring, and other 

environmental program support. Five of these labs have deployable mobile 

units that can provide chemical and biological analysis. Finally, the EPA 

has radiological response capabilities to handle some aspects of nuclear/

radiological incidents. 

The Coast Guard’s National Strike Force has three teams, located in New 

Jersey, Alabama, and California. These teams each have 36 members 

trained to the HAZMAT technician level, as well as trained members in the 

Coast Guard Reserve, and are equipped to handle major oil and chemical 

spills in coastal waters, but can also respond to other environmental 

HAZMAT emergencies. These teams have the capability to perform the 

highest level “hot zone” entry to detect and identify materials, provide site 

assessments, perform site clean up, and provide other technical assistance. 

According to Coast Guard officials, it would take about $3 million to 

upgrade these strike teams’ skills and equipment to respond to WMD 

incidents and give the federal government another asset to manage the 

consequences of a WMD.

8

The EPA regions include the same states as the FEMA regions. See app. I for the FEMA regional 

structure.
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As discussed previously, the FBI has the responsibility for crisis 

management in a WMD event. Its Hazardous Materials Response Unit is 

responsible for providing laboratory, scientific, and technical assistance to 

FBI investigations involving hazardous materials, including WMD, and 

environmental crimes. It also provides training, acts as an advisory group 

for HAZMAT crime scenes, and does WMD/HAZMAT research and 

development. The unit is trained and equipped to respond to all HAZMAT 

emergencies, including WMD, at the highest level of entry capability. It can 

detect and identify WMD or other hazardous materials using a mobile lab 

containing sophisticated, highly technical equipment that provides the level 

of evidence the FBI needs to apprehend and convict the perpetrator. In 

support of both the FBI and the local incident commander, the unit can also 

sample, package, and transport hazardous material to labs for further 

analysis, provide decontamination capability and situational assessment, 

and assist with technical scientific support and advice. The unit can 

mobilize within 4 hours and has access to FBI aircraft if the emergency is 

too far to drive to. The unit can be activated through the National Response 

System when it is thought that a crime has been committed in an 

environmental HAZMAT emergency or a HAZMAT emergency that may be a 

WMD event. 

The FBI has a new initiative to put operational HAZMAT teams in 15 of its 

56 field offices by June 1999. Each team will have 10 special agents trained 

at the HAZMAT technician level. Although these agents will not function as 

full-time HAZMAT technicians, they will be available as a quick response 

asset for gathering evidence in environmental crimes and WMD events. The 

team will be equipped to perform detection, monitoring, sampling, and 

decontamination. By the end of 1999, the FBI plans to have 4-person teams 

in the remainder of the field offices, trained to the HAZMAT technician 

level, but with very little equipment. Eight of the larger FBI teams will be in 

states that also have the National Guard RAID teams.

Concerns About RAID 

Teams’ Ability to Fully 

Meet Their 

Responsibilities

Our discussions with local, state, and federal officials and our analysis of 

the information regarding the RAID teams surfaced a number of concerns 

that the teams may not be able to meet their mission and responsibilities 

because of recruiting and retention, training, and operational issues. 
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RAID Teams May Have 

Problems Recruiting and 

Retaining Specialized 

Personnel

In 1993, the Secretary of Defense announced a major restructuring of the 

Army National Guard and the Army Reserve. As a result of the 

restructuring, combat support and combat service support functions were 

concentrated in the Army Reserve and combat functions in the Army 

National Guard. According to the Army officer commanding one of the 

support brigades responsible for training and training evaluation of Army 

National Guard and Reserve units, most of the chemical and medical units 

are in the Army Reserve. As a result, there are few chemical and medical 

positions in the Army Guard outside the RAID teams for promotion 

opportunities. In his opinion, this would make it more difficult to retain 

team members once they had been trained and were looking for career 

advancement. He, as well as others, expressed concern that the Guard 

would not be able to maintain a “pipeline” of highly trained individuals to 

fill vacancies on the RAID teams, making it necessary for the teams to 

operate at less than full capability when vacancies occur. For example, it 

may be difficult to find the highly trained personnel with the necessary 

education and skills required to operate the sophisticated equipment 

planned for the RAID teams, such as the mass spectrometer. 

Maintaining Proficiency 

Could Be a Problem

National Guard training plans for RAID team members include both 

individual and team training. Members will initially attend military training 

programs such as the U.S. Army Chemical School at Fort McClellan, 

Alabama, to give them basic specialty training in handling military nuclear, 

biological, and chemical weapons. They will also receive other military 

training, including operational radiation safety and chemical/biological 

countermeasures. The Guard also plans to send team members to the same 

types of civilian training programs that local responders from HAZMAT 

teams attend. In addition, team members will receive training on the highly 

technical equipment being purchased for detection and identification of 

WMD. Team training will include participating in exercises with other DOD 

response units, as well as local and state responders. The team will also 

plan and conduct training to learn how to operate as a RAID team. The 

National Guard plans to work with local responders to arrange for the 

RAID team to participate in their training programs and, at some future 

date, to respond to actual HAZMAT emergencies with the local teams.

According to local and federal HAZMAT team leaders, it may be difficult for 

the RAID team members to maintain their proficiency after they receive 

their training. For example, the teams will have a mobile lab with very 

sophisticated, technical identification equipment. Many local HAZMAT 

team leaders stated that they would not have some of this equipment in 
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their inventory, particularly the mass spectrometer, because it requires 

highly trained personnel to use and maintain it effectively. The federal 

HAZMAT team leaders stated that, while some of them have a mass 

spectrometer, it takes almost daily use to maintain competency and 

accuracy, which the RAID team may not get. All of the HAZMAT team 

leaders expressed concern that the RAID team members would lose their 

HAZMAT expertise and become bored if they did not have opportunities to 

continually practice their skills in more than just a simulated environment. 

All of the leaders stated that this on-the-job training is also critical to 

effective team operation. The stressful situation of an actual HAZMAT 

emergency cannot be replicated in a classroom or exercise, and team 

members need to know that everyone on the team can operate in that 

environment. The Pennsylvania Guard officer responsible for developing 

that state’s RAID team stated that the Guard was concerned about this and 

realized the need to create these on-the-job opportunities, not only to 

maintain proficiency but to keep the team members from leaving to work 

on local HAZMAT teams. He added that the Guard was working with local 

HAZMAT teams so that the RAID team could participate in local training 

exercises and, at some later point, perhaps respond with the local teams on 

actual HAZMAT emergencies.

RAID Teams May Not Be 

Available if Needed

The goal for the RAID team, either in part or as a whole, is to be able to 

deploy to a WMD incident within 4 hours of notice. All local, state, and 

federal officials we met with expressed concern that this time frame would 

get the team there too late to be useful. They stated that, for the incident 

commander to benefit from the information they could produce, the RAID 

team would be needed at the scene within the first 1 to 2 hours. After that 

time, the local/state HAZMAT teams could have the basic detection and 

identification information that would allow them to begin to handle the 

situation. Then, the incident commander would either be in control of the 

situation and not need additional assessment input from the RAID team or 

so completely overwhelmed by the enormity of the situation that the FBI 

and FEMA already would have been notified, and in coordination with the 

state, federal assets already would be on their way to the scene.

The RAID teams will have dedicated vehicles to transport them and their 

equipment to the incident. The teams will also have access to Army 

National Guard helicopters and small, fixed-wing aircraft that could carry 

some team members with hand-held equipment. The remainder of the team 

and equipment would then follow in the vehicles. To transport the entire 

team to a distant location within the state or region, with all its equipment 
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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 
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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.
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Matter for 

Congressional 

Consideration

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.

Agency Comments and 

Our Evaluation

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 
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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 
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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 
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teams was developed. We also reviewed pertinent legislation and funding 

for the RAID teams. We interviewed officials and reviewed documents from 

DOD’s Consequence Management Program Integration Office, the Army 

National Guard, Pennsylvania, and the Pennsylvania National Guard to 

determine design, implementation, and planned use of the RAID teams. 

We also discussed the RAID team concept and the implementation of that 

concept with all of the officials listed above.

We conducted our work from July 1998 through March 1999 in accordance 

with generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further 

distribution of this report until 30 days from its issue date. At that time, we 

will send copies of this report to appropriate congressional committees; 

the Honorable William Cohen, Secretary of Defense; the Honorable 

Janet Reno, Attorney General; the Honorable Rodney Slater, Secretary of 

Transportation; the Honorable James Lee Witt, Director, Federal 

Emergency Management Agency; and the Honorable Carol Browner, 

Administrator, Environmental Protection Agency. We will make copies 

available to other interested parties upon request. 

If you have any questions about this report, please contact me at 

(202) 512-5140. Robert Pelletier and Ann Borseth were major contributors 

to this report.

Mark E. Gebicke

Director, National Security

Preparedness Issues
Page 25 GAO/NSIAD-99-110 Combating Terrorism

Contents

Letter 1

Appendix I

RAID Team Locations 

Within FEMA Regions

26

Appendix II

RAID Team 

Organization and 

Staffing

27

Appendix III

Comments From the 

Department of Defense

28

Appendix IV

Comments From the 

Federal Emergency 

Management Agency

45

Related GAO Products 48

Abbreviations

DOD Department of Defense 

EPA Environmental Protection Agency

FBI Federal Bureau of Investigation

FEMA Federal Emergency Management Agency

HMRU Hazardous Materials Response Unit

HAZMAT hazardous materials

RAID Rapid Assessment and Initial Detection

WMD weapons of mass destruction
Page 26 GAO/NSIAD-99-110 Combating Terrorism

Appendix I

RAID Team Locations Within FEMA Regions ApeInxdi

States with RAID teams
Page 27 GAO/NSIAD-99-110 Combating Terrorism

Appendix II

RAID Team Organization and Staffing ApeInxdi

Operations Team

Assistant Operations Officer

Senior Operations NCO

Operations NCO-Modeling

Assistant Operations NCO

Operations Team

Assistant Operations Officer

Senior Operations NCO

Operations NCO-Modeling

Assistant Operations NCO

Administration and

Logistics Team

Logistics NCO

Administrative NCO

Administration and

Logistics Team

Logistics NCO

Administrative NCO

Communications Team

Team Chief 

Information Systems Operator

Communications Team

Team Chief 

Information Systems Operator

Medical Team

Physicians’ Assistant

Medical Operations Officer

Environmental Science Officer

Medical NCO

Medical Team

Physicians’ Assistant

Medical Operations Officer

Environmental Science Officer

Medical NCO

Commander and Deputy

Unit Commander

Deputy/Operations Officer

Commander and Deputy

Unit Commander

Deputy/Operations Officer

Survey Teams

Leader 

NBC Reconnaissance NCO

Survey Teams

Leader 

NBC Reconnaissance NCO

Survey Team

3 Assistant NBC

Reconnaissance NCOs

Survey Team

3 Assistant NBC

Reconnaissance NCOs

Survey Team

3 Assistant NBC

Reconnaissance NCOs

Survey Team

3 Assistant NBC

Reconnaissance NCOs

Legend

NCO=Noncommissioned officer

NBC=Nuclear, biological, chemical
Page 28 GAO/NSIAD-99-110 Combating Terrorism

Appendix III

Comments From the Department of Defense ApIenxdi

Note: GAO’s comments 

supplementing those in the 

report text appear at the 

end of this appendix.

See comment 1.
Appendix III

Comments From the Department of Defense

Page 29 GAO/NSIAD-99-110 Combating Terrorism

See comment 2.

See comment 3.
Appendix III

Comments From the Department of Defense

Page 30 GAO/NSIAD-99-110 Combating Terrorism

See comment 4.
Appendix III

Comments From the Department of Defense

Page 31 GAO/NSIAD-99-110 Combating Terrorism

See comment 5.
Appendix III

Comments From the Department of Defense

Page 32 GAO/NSIAD-99-110 Combating Terrorism

See comment 6.
Appendix III

Comments From the Department of Defense

Page 33 GAO/NSIAD-99-110 Combating Terrorism

See comment 7.

See comment 8.

Lret
Appendix III

Comments From the Department of Defense

Page 34 GAO/NSIAD-99-110 Combating Terrorism

See comment 9.
Appendix III

Comments From the Department of Defense

Page 35 GAO/NSIAD-99-110 Combating Terrorism
Appendix III

Comments From the Department of Defense

Page 36 GAO/NSIAD-99-110 Combating Terrorism

See comment 10.
Appendix III

Comments From the Department of Defense

Page 37 GAO/NSIAD-99-110 Combating Terrorism

See comment 11.

See pp. 22-23.
Appendix III

Comments From the Department of Defense

Page 38 GAO/NSIAD-99-110 Combating Terrorism

See pp. 22-23.
Appendix III

Comments From the Department of Defense

Page 39 GAO/NSIAD-99-110 Combating Terrorism
Appendix III

Comments From the Department of Defense

Page 40 GAO/NSIAD-99-110 Combating Terrorism

Following are our comments on the Department of Defense’s (DOD)

April 30, 1999, letter.

GAO Comments 1. During the time of our review, the plans for the Rapid Assessment and 

Initial Detection (RAID) teams evolved and we continuously met with 

Army officials to obtain the most up-to-date information on those plans. As 

we met with various organizations, we discussed our latest understanding 

of those plans. Although the plans for the teams have changed over time, 

the mission has not. As stated in the report, the various officials we met 

with expressed concerns with the mission and the time it would take the 

RAID team to respond to a weapons of mass destruction (WMD) event. 

2. We have done extensive work in the area of WMD consequence 

management, which involves the complex federal response system and its 

requirements, and have gained considerable understanding of that system. 

We have included a partial list of our recent products on WMD 

consequence management at the end of this report. For this assignment, 

we have also discussed the federal response system and its requirements to 

mitigate the effects of a WMD attack with the Federal Emergency 

Management Agency (FEMA) and the Federal Bureau of Investigation 

(FBI), which are the lead agencies for the federal response system, and 

other agencies intimately involved as part of the federal response system.

3. Our focus was on the RAID teams and not DOD’s total capacity to 

respond to WMD. We discussed the RAID teams’ roles and responsibilities 

with officials who 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 officials were aware of the 

RAID team concept, most had been briefed on the concept, and several had 

provided comments to DOD on that concept. We agree with DOD that a 

complete, current, and accurate assessment of the roles and mission of the 

RAID teams is needed to validate the requirement for these teams and the 

contributions they can make in support of the nation’s first responder 

community. DOD’s position is consistent with our recommendations.

4. We have clarified the report to reflect that DOD has articulated the 

specific mission of the RAID teams. However, officials from FEMA and the 

FBI, as well as other federal officials who are intimately involved in the 

complex WMD federal response system, questioned the need for the RAID 

teams because of the federal structure already available to respond to 

WMD incidents. They also expressed concern about the RAID teams’ 
Appendix III

Comments From the Department of Defense

Page 41 GAO/NSIAD-99-110 Combating Terrorism

impact on first responders, if the teams do not arrive for several hours after 

the incident occurs. As we state in the report, we found differing views of 

the RAID team role at the state and local levels. For example, Pennsylvania 

Emergency Management Agency officials are integrating the state’s RAID 

team into the state’s WMD response plans. However, the other states we 

talked to without RAID teams did not mention any efforts to include the 

regional team into their plans. 

5. As mentioned in comment 3, our focus was on the RAID teams, not 

DOD’s total response capability. We did not portray the RAID teams as 

meeting all the support requirements expected from DOD as DOD implies 

in its comments. We assessed the teams against their stated roles and 

responsibilities and not against DOD’s total support requirements. 

Therefore, we believe our assessment is valid.

6. We agree that the solution to the WMD response mission requires a 

military and civilian partnership and existing capabilities must be 

leveraged. However, it appears that DOD is not taking full advantage of 

leveraging existing capabilities. For example, DOD is creating RAID teams 

in the Army National Guard when considerable capability already exists in 

the Air National Guard and, with some upgrading of skills and equipment, 

could perform comparable missions. Also, DOD is creating teams to 

perform functions that can be performed by numerous local, state, and 

federal organizations. As stated in our report, if governmentwide priorities 

have not been established and funding requirements have not been 

validated based on an analytically sound threat and risk assessment, there 

is no reasonable assurance that funds are being spent on the right programs 

in the right amounts and that unnecessary program and funding 

duplication, overlap, misallocation, fragmentation, and gaps have not 

occurred.

7. DOD has a significant support role in domestic WMD response. If a 

WMD event occurs, DOD will likely be called on to support the federal 

response just as it has done in other national emergencies. As we state in 

the report, both the FBI and FEMA questioned the use of the RAID teams in 

a federal response, and there are differing views on how the teams can be 

used in a state role. Therefore, we suggest that the key federal agencies 

determine if the RAID teams are needed for the numerous reasons cited in 

the report. The DOD response did not address one of the major issues 

surrounding the role and use of the RAID teams—that of response time. 

Many of the concerns expressed by federal, state, and local officials center 

on the length of time it may take the RAID team to arrive at a WMD 
Appendix III

Comments From the Department of Defense

Page 42 GAO/NSIAD-99-110 Combating Terrorism

emergency. According to these officials, there are other federal assets with 

similar capabilities or access to contractors with similar capabilities that 

could respond as quickly or quicker than the RAID team.

8. According to FBI officials, the primary role of the FBI’s Hazardous 

Materials Response Unit (HMRU) is to support criminal investigations. 

However, it can assist incident commanders with the same types of 

information that the RAID teams would provide. Also, although it is a 

unique national asset, it can respond quickly by air or ground to wherever it 

is needed. Moreover, there are many federal units beyond the FBI’s HMRU 

that can provide similar capabilities to the RAID team, but were not 

considered when the RAID teams were created and not mentioned in 

DOD’s comments on this report. 

Local hazardous materials (HAZMAT) teams do not routinely deal with 

militarized chemical agents, but as we state in the report, they can use 

basic identification techniques and equipment to begin to assess and 

respond to the incident. Federal, state, and local HAZMAT teams are 

experienced in identifying and handling very toxic industrial chemicals in 

the same family as the military agents. DOD does not address the 

statements made by HAZMAT officials that their teams do not need the type 

of sophisticated equipment that the RAID team will have to begin to handle 

the event. 

According to local, state, and federal officials, a biological incident would 

likely play out through the medical community, not the HAZMAT response 

system, unless the terrorists immediately announced the action. Even with 

knowledge of a possible biological agent present, someone operating the 

sophisticated equipment the RAID team brings to a scene will be able to 

detect that a biological agent has been released, but will not be able to 

positively identify the agent. 

According to Army officials, the primary mission of the RAID team’s 

medical unit is to provide medical assistance to the RAID team members 

and, secondarily, to provide medical advice to first responders. There are 

many other federal entities that can also provide this advice, either on 

scene or by telephone, to the incident commander.

Army Reserve chemical companies can detect chemical and biological 

agents. According to U.S. Army Reserve officials, the units discussed in the 

report can be used in more than a wartime situation and, in fact, can be 

prepositioned at events, such as the Olympic games, or used in a WMD 

emergency along with other federal and military assets.
Appendix III

Comments From the Department of Defense

Page 43 GAO/NSIAD-99-110 Combating Terrorism

9. We discuss the states’ requests for RAID teams on page 22 of this report. 

Although DOD said that HAZMAT teams do not have the “basic capability 

to detect and identify industrial chemicals and mitigate the effects of a 

chemical emergency”, this is exactly what they are trained to do. The 

statement by the president of the International Association of Fire Chiefs 

before the Research and Development Subcommittee of the House 

National Security Committee in March 1998 cited in DOD’s comments must 

be considered in context. In outlining first responder shortfalls in 

equipment and training, he was referring to the handling of WMD incidents, 

not industrial chemicals, which the Domestic Preparedness Program is set 

up to overcome. And, even though some first responders may lack WMD 

response capabilities, International Association of Fire Chiefs officials, as 

well as the local HAZMAT team members and federal response team 

officials we spoke with, reinforced the fact that many HAZMAT teams have 

the basic skills to begin to mitigate a chemical WMD attack. We do not 

state that these teams may not need outside support to mitigate the effects 

of a catastrophic WMD event.

The individuals we spoke with, including the Chief of Hazardous Materials 

for the Chicago Fire Department, recognized that the National Guard is 

invaluable in its traditional role, providing support such as transportation 

and area security. However, he and others reinforced the fact that the 

capability for initial detection and identification of a WMD needs to be in 

the first responder community, not in a team that may not respond for 

hours.

10. We do not state or imply in the report that maintaining the strength of 

Active Guard and Reserve positions is a “problem.” Our report discussed 

the potential problem of finding and retaining people with the high level of 

skill or education needed to handle the sophisticated equipment the RAID 

teams will have and those with the appropriate skills to staff the medical 

team. Specifically, the RAID teams are to receive highly specialized 

training, which is well beyond the training received by individuals in 

military chemical units and the National Guard RAID (Light) units. Also, 

some functions will require individuals with the necessary education and 

skills to operate sophisticated equipment. Replacing these individuals 

when vacancies occur might take time, which could affect the teams’ 

capabilities.
Appendix III

Comments From the Department of Defense

Page 44 GAO/NSIAD-99-110 Combating Terrorism

11. Both Army and Pennsylvania National Guard officials stated their 

concerns to us regarding the need for RAID team members to maintain skill 

proficiency. Our report recognizes that the National Guard plans to work 

with local responders to arrange for the RAID teams to participate in their 

training programs and that the Pennsylvania National Guard is working 

with local and state HAZMAT teams to create training opportunities. 
Page 45 GAO/NSIAD-99-110 Combating Terrorism

Appendix IV

Comments From the Federal Emergency 

Management Agency ApVenIxdi

Note: GAO’s comment 

supplementing those in the 

report text appear at the 

end of this appendix.

See comment 1.
Appendix IV

Comments From the Federal Emergency 

Management Agency

Page 46 GAO/NSIAD-99-110 Combating Terrorism

The following is GAO’s comment on FEMA’s letter dated April 30, 1999.

GAO Comment 1. Based upon the written technical comments supplied by FEMA, we have 

revised the report as appropriate.
Page 47 GAO/NSIAD-99-110 Combating Terrorism
Page 48 GAO/NSIAD-99-110 Combating Terrorism

Related GAO Products

Combating Terrorism: Observations on Biological Terrorism and Public

Health Initiatives (GAO/T-NSIAD-99-112, Mar. 16, 1999).

Combating Terrorism: Observations on Federal Spending to Combat

Terrorism (GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).

Combating Terrorism: FBI’s Use of Federal Funds for CounterterrorismRelated Activities (Fiscal years 1995-98) (GAO/GGD-99-7, Nov. 20, 1998).

Combating Terrorism: Opportunities to Improve Domestic Preparedness

Program Focus and Efficiency (GAO/NSIAD-99-3, Nov. 12, 1998).

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: Federal Agencies’ Efforts to Implement National

Policy and Strategy (GAO/NSIAD-97-254, Sept. 26, 1997).

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