Challenges to Leadership: 

Responding to Biological 

Threats 

Paul Rosenzweig

Center for Technology and National Security Policy 

National Defense University 

October 2011 
The views expressed in this article are those of the author and do not reflect the official policy or 

position of the National Defense University, the Department of Defense or the U.S. Government. 

All information and sources for this paper were drawn from unclassified materials. 

Paul Rosenzweig is Principal, Red Branch Consulting, PLLC, and Professorial Lecturer in Law, 

George Washington University School of Law. He served as Deputy Assistant Secretary for 

Policy in the Department of Homeland Security and twice as Acting Assistant Secretary for 

International Affairs. In these positions he had responsibility for developing policy, strategic 

plans, and international approaches to the entire gamut of homeland security activities, ranging 

from immigration and border security to avian flu and international data protection rules. 

He serves as a Senior Editor of the Journal of National Security Law & Policy and on the Board 

of Advisors for the Hanover College Center for Free Inquiry. He is a cum laude graduate of the 

University of Chicago Law School. He has an M.S. in Chemical Oceanography from the Scripps 

Institution of Oceanography, University of California at San Diego and a B.A from Haverford 

College. Following graduation from law school, he served as a law clerk to the Honorable R. 

Lanier Anderson, III of the United States Court of Appeals for the Eleventh Circuit. 

Acknowledgments 

The author expresses his thanks to Dr. James J. Valdes and to an anonymous reviewer for their 

thoughtful review of the paper and their contributions to it. Thanks also to Nicholas Rueter, a 

J.D./M.A. candidate at Duke University, for his able research assistance and to the Center for 

Technology and National Security Policy for funding this research. 

Defense & Technology Papers are published by the Center for Technology and National Security 

Policy, National Defense University, Fort Lesley J. McNair, Washington, DC. CTNSP 

publications are available at http://www.ndu.edu/ctnsp/publications.html. 

ii
iii

Table of Contents

 Introduction 1 

I. A Prelude –The Biological Threat In Context 2

II. The Evolution of U.S. Biodefense Policy 4 

III. A Confusion of Federal Responsibility 6

III. Threshold Challenges: State to Federal Responsibility and 

the DHS/HHS Question 18 

IV. Recommendations 26 
Introduction

Experts have been warning of the threat of a biological attack on the United States for many 

years. In the aftermath of the 2001 anthrax release, various agencies within the Federal 

government initiated a series of programs intended to prevent incidents and ameliorate the 

perceived threat. State and local first responders have also invested heavily in systems and 

mechanisms for responding to an unanticipated disease outbreak. Private sector actors (hospitals, 

doctors, vaccine providers, and others) have mobilized to enhance their readiness, resilience, and 

capacity to respond. After nearly 10 years of political, legal and practical ferment, many have 

recognized the need to take stock of our efforts thus far and to assess how effective they have 

been. 

The proliferation of authorities and responsibilities in the arena of biological threats is not well 

documented. No comprehensive survey of programs and responsibilities exists.1

 Indeed, the field 

is so broad that any review of modest length risks either degenerating into platitudes or 

reviewing efforts at such a high level of generality that any conclusions and recommendations 

are of little practical value. Accordingly, this monograph has set a more modest goal. It seeks to 

identify a series of gaps and overlaps in existing structures and mechanisms and to advance 

potential solutions that can be implemented. In particular, this monograph examines two issues 

of concern: 

• Federal Coordination Structure—Any fair examination suggests that at this juncture the 

proliferation of responsible Federal entities has bred a form of bureaucratic gridlock that 

is detrimental to effective decision-making. The Federal government lacks an effective 

centralizing coordinating function for biological incidents. Roles and responsibilities can 

be readily confused and authorities to act are often ambiguous. 

• Federal/State Coordination—Few fully understand when, and how, a transition from an 

event of local significance to one constituting an event of national significance occurs. 

No concerted effort has been made to understand where the threshold for dividing 

Federal responsibility from State/local/private responsibility lies, nor when transitions of 

responsibility within the Federal government should occur. 

With respect to both of these areas, this monograph seeks to identify certain gaps and overlaps 

that need resolution if the goal is effective action. In doing so, the paper seeks as well to outline 

some suggested solutions. In particular, the paper recommends that a more comprehensive set of 

planning and response exercises be developed in order to better understand and develop a 

doctrine of incident leadership suitable for a biological crisis. 

1

                                                           

1 One useful survey, limited to international programs, can be found in Barry Kellman, Michael Kraft, Zachary 

Clopton & Orley Lindgren, United States Policies and Programs to Reduce Bio-Dangers (ISBI, March 2010) 

[available at 

http://www.biopolicy.org/sites/default/files/documents/ISBI%20Congressional%20Report%20Final.pdf].
I. A Prelude—The Biological Threat In Context

There is, of course, a substantial debate regarding the scope and nature of the threat of a 

biological attack. Some observers consider the threat to be significant and, to a large degree, 

greater than has been recognized. For example, the Commission on the Prevention of WMD 

(Weapons of Mass Destruction) Proliferation and Terrorism concluded that: 

“Unless the world community acts decisively and with great urgency, it is more 

likely than not that a weapon of mass destruction will be used in a terrorist attack 

somewhere in the world by the end of 2013. 

The Commission further believes that terrorists are more likely to be able to 

obtain and use a biological weapon than a nuclear weapon.”2

 

Others, by contrast, contend that the threat from a deliberate biological incident is overstated. As 

one working group of scientists put it: 

“Public health in the United States faces many challenges; bioterrorism is just 

one. Policies need to be crafted to respond to the full range of infectious disease 

threats and critical public health challenges rather than be disproportionately 

weighted in favor of defense against an exaggerated threat of bioterrorism.”3 

What then, is the likelihood of a biological threat, and how might it compare with the probability 

and consequence of other known threats? It is, as with so many risk assessments in the area of 

terrorism, difficult to offer a definitive answer to these questions. While our vulnerability to, and 

the consequences of, a biological incident can be assessed with a moderate degree of confidence, 

quantifying the nature of the threat remains deeply problematic. There are, however, a number of 

guideposts to a realistic threat assessment that we can identify with some certainty: 

First, some terrorists have affirmatively considered using biological agents as part of their 

activities. As a posting on one web site put it: “Biological weapons are considered the least 

2

                                                           

2

 The Commission on the Prevention of WMD Proliferation and Terrorism, World at Risk: The Report of the 

Commission on the Prevention of WMD Proliferation and Terrorism, (December 2008), xv.. Richard Danzig, a 

former senior DoD official has reached much the same conclusion. See Richard Danzig, Catastrophic Bioterrorism: 

What Is to Be Done? Center for Technology and National Security (National Defense University, August 2003). 3

 Scientists Working Group on Biological and Chemical Weapons, Center for Arms Control and Non-Proliferation, 

Biological Threats: A Matter of Balance (January 26, 2010); see also Milton Leitenberg, Assessing the Biological 

Weapons and Bioterrorism Threat (Strategic Studies Institute, U.S. Army War College, 2005). 
complicated and the easiest to manufacture of all weapons of mass destruction. ... The 

destructive power of these [biological] weapons is no less than that of nuclear weapons.”4

Second, biological weapons are comparatively more cost-effective in creating casualties than 

other weapons. According to the Stockholm International Peace Research Institute, it costs 

roughly $2,000 per square kilometer to inflict civilian casualties with conventional weapons, 

$800 with nuclear weapons and only $1 with a biological weapon.5

 This favorable cost leverage 

factor makes a biological attack an attractive option for those with malevolent intent and limited 

financial resources. 

Third, though often difficult and complicated to achieve in practice, the creation of a biological 

attack agent is technologically feasible. Surveys published by the American Medical Association 

have identified potential biological agents including anthrax, botulism, Ebola, plague, ricin, 

smallpox and others that can be developed and deployed with lethal effect.6

 More significantly, 

we have actual experience with a biological agent being used in an attack, most recently with the 

anthrax releases in 2001.7

Finally, beyond human casualties, we know that the financial costs of a successful biological 

attack are likely to be significant. For example, the World Health Organization has estimated that 

a 50-kilogram anthrax attack on a city of five million would result in as many as 250,000 

casualties. The Center for Disease Control’s economic models put the costs at more than $25 

billion for every 100,000 persons exposed.8

All of which is not to say that biological attacks are more likely to occur or are the greatest threat 

to our security, overall. Given the frequency with which cyber attacks occur, for example, it 

might be more productive to focus priorities on countering cyber incidents.9 Likewise, the 

potentially devastating effects of a nuclear incident and the likely even greater economic costs 

associated with such an event might suggest prioritizing the development of nuclear detection 

3

                                                           

4

 This quote is from the Jihadi Lion’s Den Website, al-Ma’asada al Jihadiya (quoted in Barry Kellman & Zachary 

Clopton International Anti-Bioviolence Initiatives, (May 2009) at v, [available at 

http://www.biopolicy.org/sites/default/files/documents/International%20Anti-Bioviolence%20Initiatives_HSI.pdf].

5

 Barry Kellman, Bioviolence, (Cambridge Univ. Press 2007), 16 n.2. 6

 Beginning in 1999 the Journal of the American Medical Association published a series of articles relating to 

biological agents as threats. Typical is “Hemorrhagic Fever Viruses as Biological Weapons: Medical and Public 

Health Management,” Journal of the American Medical Association, May 8, 2002, Vol. 287, No. 18 . 7

 A summary of the FBI’s investigation of the Amerithrax attacks is available at http://www.fbi.gov/aboutus/history/famous-cases/anthrax-amerithrax/amerithrax-investigation. 8

 Kellman, Bioviolence, 34. 9

 The Deputy Secretary of Defense has said that American cybersystems are probed thousands of times every day. 

See William J. Lynn, III, “Defending a New Domain: The Pentagon’s Cyberstrategy,” Foreign Affairs, 

September/October 2010, 97, http://www.cfr.org/publication/22849/defending_a_new_domain.html.
technology. 10 With all of these high-consequence, low-frequency events, comparative risk 

analysis is challenging and, in the end, based on somewhat subjective judgments. 

Plainly any discussion about organizational challenges faced by the Federal government (and its 

State, local and private partners) in responding to a biological threat begins, at least implicitly, 

from the premise that the threat is both real and significant. Therefore action to prevent the threat 

is necessary. Those who do not concur in the assessment of the threat will consider many of the 

difficulties identified in this report to be of lesser significance and will view the need to correct 

those deficiencies with less urgency. 

II. The Evolution of U.S. Biodefense Policy 

In the years since September 11, 2001 the United States has begun the process of defining the 

functions and capabilities required for our efforts in the bio-threat arena. At the strategic level, 

there has been a steady evolution of thinking regarding how those functions should be 

characterized. The results of that evolution have been incorporated into the strategic objectives of 

our activities. The trend has been a shift from a “pure threats/terrorism” model to one 

recognizing the “dual use” character of biological agents. 

In 2004, President Bush released the first biodefense strategy, “Biodefense for the 21st

Century.”11 Focused exclusively on the threat of a biological attack, the strategy characterized 

the “public health philosophy of the 20th Century - emphasizing prevention” as ideal for dealing 

with natural disease outbreaks, but insufficient for addressing deliberate threats that were part of 

a campaign of aggression or terror. 

To counter those types of deliberate threats, the Bush-era strategy advanced measures that fall 

into the now common model for dealing with potentially catastrophic terrorist events—Federal 

efforts would center around the four pillars of “Prepare, Prevent, Respond, and Recover.”12

Thus, the Bush strategy emphasized functions of: intelligence collection; threat analysis; 

proactive prevention; critical infrastructure protection; attack warning; attribution; response 

planning; medical countermeasures; and decontamination. In short, the functional structure was 

modeled on the same structures that might apply to any terrorist threat of significance. 

4

                                                           

10 One study has put the cost of a one-kiloton bomb exploding in New York at in excess of $1 trillion. See 

Veronique de Rugy, “Applying Strategic Risk Management to Allocating Resources for Homeland Security: A Case 

Example of Port Security,” Strategic Risk Management in Government: A Look at Homeland Security (New York: 

IBM 2009).

11 Homeland Security Presidential Directive-10: Biodefense for the 21st Century, [available at 

http://www.fas.org/irp/offdocs/nspd/hspd-10.html].

12 HSPD-10 characterized the functions slightly differently as Threat Awareness, Prevention and Protection, 

Surveillance and Detection, and Response and Recovery, but the parallel to structures in place for dealing with 

virtually any potentially catastrophic terrorist incident are undeniable.
By contrast, the Obama Administration’s November 2009 “National Strategy for Countering 

Biological Threats” more broadly recognized that biological issues involve dual use 

technology.13 It began from the premise that the overwhelming majority of life science advances 

will have predominantly beneficial effects, albeit with significant risk of malfeasant uses. As a 

consequence, while maintaining a focus on the counter-terrorism functions of detecting and 

preventing biological attacks (and preparing to respond and recover if prevention efforts fail), the 

strategy broadened the focus of preventative efforts to encompass activities that are intended to 

address the behavior of law-abiding life scientists—that is, it sought to reach out to life science 

actors who are in a position to participate in and foster non-proliferation activities, and to seek 

their assistance. Rather than focus exclusively on active prevention by identifying and capturing 

malfeasant actors, the strategy also intends to educate law-abiding life scientists about the risks 

of their activities with the intent of minimizing those risks. 

The Obama strategy sought to change the prevention paradigm by adding functions such as 

“reinforcing norms of safe and responsible conduct” and “transforming the international dialogue 

on biological threats.” Perhaps of even greater significance, this strategy, unlike that of 2004, 

recognizes the positive value of biological life science products, both on their own terms and as a 

means of promoting and enhancing global health security. In short, the newer strategy posits that 

our response to naturally-occurring infectious disease is of relevance to our preparation for, and 

response to, a deliberate biological attack. 

In addition to clarifying this paradigm evolution, it is necessary to better understand the risks and 

how we might ameliorate them. Part of this understanding could come from a taxonomy of 

functions relating to biological threats, since in the biological domain (as much, if not more so 

than in other policy arenas) Federal efforts operate along several different tracks. To that end, it 

is helpful to identify certain subcategories of potential biologically-related activities for purposes 

of assessing the utility of current structures and processes. Using the current strategy as a 

template, one can identify several distinct types of activity. 

Within the prevention domain, these might include: 

• Threat Reduction –Education efforts; restriction of access to certain technologies or 

knowledge; control of source materials; research oversight; and development of 

situational awareness, all designed to prevent the spread of the capability to construct 

biological weapons. 

• Intelligence and Counter-intelligence collection—The collection of intelligence on the 

intent and capabilities of those who might seek to conduct a biological attack and the 

counter-surveillance and risk mitigation activities designed to prevent adversaries from 

5

                                                           

13 National Strategy for Countering Biological Threats (November 2009) [available at 

http://geneva.usmission.gov/wp-content/uploads/2009/12/Natl-Strategy-for-Countering-BioThreats.pdf].
gaining an understanding of vulnerabilities in the United States to particular pathogens or 

attack vectors. 

• Counter-terrorism—Measures involving law enforcement, military, paramilitary, and 

homeland security assets intended to deter or interdict an intended biological attack. 

Within the context of preparation and response one can think of the functions to be performed in 

any number of ways. The simplest, and most common, is to follow the characterization used by 

both the Bush and Obama Administrations: 

• Preparation—Federal, State, and local efforts in advance of a biological event, 

encompassing everything from pre-event planning, exercises, and vaccinations to general 

public health measures, to the pre-positioning of medical stockpiles. 

• Detection—The creation and operation of bio-surveillance systems for the detection of 

biological agents and the development of information sharing systems within the public 

health community to identify and characterize new outbreaks. 

• Event Characterization—Efforts to determine the location of the impacted community at 

the time of an undetected release (as, for example, an aerosolized dispersal) and the 

location of the current hazard zone (which may have moved in the 24-36 hours from the 

time of the release until the time of detection/confirmation). These may represent two 

very different but equally significant “plume” zones, which will require characterization. 

• Medical Counter-measures—The development of responsive vaccines and the 

distribution of vaccines and antibiotics to the civilian population on an outpatient basis. 

• Mass Casualty—Medical efforts to prevent loss of life, and respond to illness, 

psychological trauma, and to contain the spread of potentially contagious diseases. 

Provision of timely preventive treatments such as antibiotics or vaccines for the purpose 

of saving lives, protecting scarce medical capabilities, and preserving social order. 

• Decontamination—The development and application of decontamination and 

remediation standards, protocols, and capabilities to address the risks of contamination 

following a biological weapons attack and strategies, guidelines, and plans for 

decontamination of persons, equipment, and facilities. 

III. A Confusion of Federal Responsibility

Given the broad current scope of the American strategy, the dangers of fragmentation (lack of 

coordination) are even greater than they were when a solely preventative strategy was being 

6
pursued.14 What is missing from the taxonomy presented above, and what is missing from the 

current bio-threats strategy, is any sense of the need for a significant coordination role within the 

Federal government. This shortfall can be observed in at least two distinct situations: 1) the lack 

of a strong Federal coordinator at the White House and 2) the lack of clarity in the respective 

roles of the Secretaries of Health and Human Services and Homeland Security in preparing for 

and preventing a biological attack, as well as their role in interacting with other Federal 

institutions such as DOJ/FBI and the IC.15

A survey in 2004 identified more than 25 Presidentially-appointed and Senate-confirmed 

positions in the Federal government with responsibility for organizing the Federal response to 

biological threats.16 Counting senior career and political appointees, that same survey identified 

more than 80 senior officials scattered through the Departments of Health and Human Services 

(HHS), Homeland Security (DHS), Agriculture (USDA), the Department of Justice (DOJ) and 

the Federal Bureau of Investigation (FBI), Commerce, State, Defense (DoD), the Intelligence 

Community (IC), and the Environmental Protection Agency (EPA), who share responsibility for 

ensuring that America is not subject to a biological attack or, if such an attack occurs, for 

ensuring that America is prepared to respond effectively.17 These senior leaders manage 

organizations whose staff size is not precisely known, but which logically run into hundreds, if 

not thousands of people.18

The threat from biological incidents is multivariate and complex. It is, therefore, both logical and 

sensible to have a number of different Federal institutions with responsibility for addressing the 

problem.19 But in the absence of a clear set of policy directions and the mechanisms for 

coordinating action across Federal agencies, a risk is incurred that Federal polices will be 

confused in development or poorly executed in practice. 

7

                                                           

14 As Richard Danzig has noted, the fragmentation problem is not solely an issue of homeland/national security. 

Rather, it is equally true that the Federal biological and medical responses are dispersed across a number of agencies 

and within the Department of Health and Human Services where the HHS Secretary must coordinate the National 

Institute of Health, the Biological Advanced Research and Development Agency, the Centers for Disease Control 

and Prevention (CDC), the Food and Drug Administration (FDA), the Public Health Service and the Office for 

Emergency Preparedness and Response. See Danzig, Policymaker’s Guide, 15– 16. 15 The same lack of clarity is present when determining the roles of the two Secretaries in responding to a successful 

biological attack. The challenges in the “respond and recover” domain are addressed in the next section. 16 Ari Schuler, Joseph Fitzgerald, Thomas Inglesby & Tara O’Toole, “Executive Government Positions of Influence 

in Biodefense: The Bio Plum Book, Biosecurity and Bioterrorism: Biodefense Strategy,” Practice and Science 4:2 

328 (2004), [available at http://www.upmc-biosecurity.org/website/resources/publications/2004_origarticles/2004_article_pdfs/2004-12-15-execgovtpositionsbio-plumbook.html.pdf].

17 Ibid.

18 Though the technical microbial expertise within the Federal government is small compared to that in the private 

sector, this monograph suggests the number of individuals with responsibilities related to biological threat 

prevention, detection, and response is much greater than the simple catalog of those with the requisite scientific 

expertise to diagnose the attack at a technical level.

19 The challenge is further magnified when one realizes that the primary responsibility for preparedness and 

response lies with State and local authorities who manage State-level health systems and that the delivery of a 

response ultimately relies on a complex web of private sector actors. The transition from State to Federal 

responsibility is addressed in the next section.
The proliferation of responsible agencies suggests the need for a well-defined set of 

organizational structures and procedures to develop and implement policies regarding biological 

threat prevention, preparedness and response. These structures should, of course, be optimally 

designed to implement the chosen underlying policies adopted by the Federal government. 

High-Level Federal Coordination: The current bio-threats strategy focuses principally on 

prevention and makes little mention of a Federal coordinating function, implicitly assigning that 

function to existing coordinating mechanisms within the National Security Council (NSC). 

Contrast that silence with the Obama administration’s approach to cyber security policy. In that 

context, the complexity of the coordination task was highlighted by the principal 

recommendation of President Obama’s Cyber Space Policy Review, a comprehensive review of 

American cyber policy undertaken at the start of the President’s administration.20 The Review 

called for the appointment of a White House-level policy coordinator (colloquially knows as a 

“Cyber Czar”) who would “anchor” leadership on cyber issues within the White House.21

Indeed, the need for leadership was so palpable that the Review’s first chapter was entitled 

“Leading from the Top.”22 

The current approach to biological threats reflects only a partial recognition of the need for 

greater coordination. At the highest levels, the President has appointed a senior official in the 

NSC with responsibility for coordinating Federal efforts in arms control, the proliferation of 

weapons of mass destruction (WMD) and terrorism.23 But the official responsible for 

coordinating efforts to prepare for and respond to the use of WMD has responsibilities that are 

broader than the response to biological threats. Those organizational responsibilities also include 

such (very significant) concerns as nuclear non-proliferation matters. Thus, even with this highlevel attention, the salience of the Federal response to the biological threat is diluted by the need 

to be attentive to other notable threats. 

Operational Counter-Terrorism Coordination: The situation is likewise a muddle when one 

looks at the next level down and considers the large number of officials who are responsible for 

preparing for and addressing purposeful biological threats before they occur. At an operational 

level, this makes coordination challenges significant. These challenges cross functions (such as 

intelligence and law enforcement, threat reduction and detection); these challenges cross 

institutions (such as the judiciary and the military). 

                                                           

20 Executive Office of the President, Cyber Space Policy Review: Assuring a Trusted and Resilient Information and 

Communications Infrastructure (May 2009). 21 Cyber Space Policy Review, 7; vi (recommendation #1, calls for appointment of NSC-level policy cyber 

coordinator).

22 Responding to this call, in December 2009, President Obama appointed Howard Schmidt as the first Special 

Assistant to the President and Cybersecurity Coordinator.

8

23 The appointment of such an official was called for by the Commission on the Prevention of Weapons of Mass 

Destruction Proliferation and Terrorism, co-chaired by former Senators Bob Graham and James Talent. See 

Prevention of WMD Proliferation and Terrorism Report Card (January 2010) [available at 

http://www.preventwmd.gov/static/docs/report-card.pdf].
Intelligence and Law Enforcement Activities Overseas—There are a number of different 

actors who are responsible for the collection and analysis of information related to biological 

threats that originate overseas (activities that, in the taxonomy, would constitute counterterrorism and counter-intelligence activities). Principal responsibility for the intelligence 

collection aspects of these activities resides, naturally enough, with our intelligence agencies. 

Any successful effort to collect and analyze biological threat intelligence will necessarily involve 

the coordination of the intelligence activities of the Central Intelligence Agency (CIA), military 

intelligence activities of the Defense Intelligence Agency, and signals intelligence from the 

National Security Agency (NSA),24 as well as internationally-based law enforcement assets 

deployed by the Department of Justice/FBI and DHS. 

Strategic-level IC-wide coordination of these activities is the responsibility of the Office of the 

Director of National Intelligence (ODNI) which, broadly speaking, is responsible for setting 

intelligence collection and analysis priorities based upon the requirements articulated by the 

consumers of its products. To assure that biological threats are particularly scrutinized, the ODNI 

has a directorate tasked with examining the Global Biological Threat within the National 

Counter-Proliferation Center (NCPC).25

To accomplish its coordination mission, the NCPC has developed strategies intended to focus 

intelligence collection and analysis on current and projected WMD proliferation issues. It also 

attempts to evaluate the scope of existing knowledge about threats with an eye toward 

eliminating critical intelligence gaps on the U.S. Government’s highest priority WMD 

proliferation concerns. Most notably, in response to a recommendation from the WMD 

Commission,26 it has created and chartered the Biological Sciences Experts Group to tap the 

expertise of our nation’s scientific talent in academia and industry to address biological threats. 

The focus remains largely “intelligence, “ rather than “science,” driven, and the IC’s relative lack 

of direct experience with biological agents and the underpinning science and technology can 

result in unrealistic threat assessments. 

Despite these efforts, intelligence collection and analysis of biological threat information remains 

a challenge. Our record of detecting biological threats is poor at best, and at times is even 

counter-productive and erroneous.27 As one senior intelligence officer told the WMD 

9

                                                           

24 The basic architecture of the intelligence community was first defined in the National Security Act of 1947 and 

most recently revised in the Intelligence Reform and Terrorism Prevention Act of 2004. The core definition of the 

authorities and limitations of the intelligence agencies is particularized in Executive Order 12333, first adopted by 

President Reagan in 1981 and subject to many revisions since.

25 A fuller description of the work of the NCPC can be found at http://ncpc.dni.gov/ 26 The WMD Commission (also sometimes called the Silberman-Robb Commission) is the colloquial name for The 

Commission on the Intelligence Capabilities of the United States Regarding Weapons of Mass Destruction. For this 

particular recommendation, see Commission Report to the President (March 31, 2005) 510. The existence of a 

biological directorate within the NCPC was another recommendation of the Commission. Ibid. 512. 27 The most notable example of this latter fact was our over-reliance on an agent, code named “Curveball” who quite 

literally conned our intelligence services into believing that Iraq had a biological weapons program. Bob Drogin, 

Curveball: Spies, Lies and the Con Man Who Caused a War (Random House, 2007).
Commission: “We do not understand biological weapons better now than five years ago: five 

years from now, we will understand them less well.”28 This is due in large part to the fact that 

there remain few scientists and engineers—“weaponeers”—who have actual hands-on 

experience with these weapons and who understand their limitations. 

The problem is exacerbated when the geographic location of the potential threat changes from 

nation states outside the U.S. borders with whom we have no close relation, to one where the 

threats arise in or are transiting allied nation states (e.g., European nations or Japan). In many of 

these allied nations, for example, the FBI works cooperatively with foreign law enforcement to 

track weapons of mass destruction.29 Similarly, the DHS typically engages with international 

partners to jointly enhance border security.30 These cooperative law enforcement activities must 

be coordinated with and layered on top of existing intelligence sharing agreements and 

traditional military-to-military cooperative activities.31

Collectively, these several efforts represent a significant investment of American resources in 

cooperative counter-terrorism. At least in theory, all of these efforts are coordinated locally 

through the U.S. Embassy and, in Washington, through the NSC. But here again, the 

infrastructure for effective coordination of our response to biological threats is lacking. In each 

American Embassy there is a coordinative mechanism for law enforcement activity generally, 

but biological threats are subsumed within the everyday concerns of counter-narcotics and 

military training. 

Nowhere in the multitude of agencies is there an overall operational coordinator. The closest 

analog would be the State Department’s Bureau of International Security and Nonproliferation 

but, even within the State Department, that Bureau must coordinate its efforts with other 

Bureaus, including Intelligence and Research, Counterterrorism and International Narcotics and 

Law Enforcement. The coordination challenge overseas merely becomes magnified as the 

operatives of additional agencies (DOD, DOJ and DHS) are also involved. Though their 

activities in foreign countries must, de jure, be coordinated with the U.S. Ambassador in that 

country, in practice the absence of a strong coordinative function in Washington has a “trickle 

10

                                                           

28 Commission Report, 506.

29 The FBI’s overseas engagement can occur through the local Legal Attache, seconded to the US embassy. In many 

instances, however, the substantive expertise will come from dedicated counter-terrorism and weapons of mass 

destruction investigators primarily based in the United States.

30 Overseas border control programs operated by the Department range from cooperative inspection programs (like 

the Container Security Initiative) to data-collection programs (like the Electronic System for Travel Authorization) 

to immigration systems (like the Immigration Advisory Program).

31 For example, since WWII, the United States and the United Kingdom have had a cooperative relationship 

regarding the sharing of signals intelligence. In subsequent years, the agreement (known as the UKUSA Agreement) 

was broadened to include sharing with Australia, Canada, and New Zealand.
down” effect overseas.32 The reality is a lack of focus and attention, perhaps because in relation 

to other more tangible and visible threats, biological threats seem remote. 

Domestic Law Enforcement—The situation is rather better structured when we turn our 

attention to domestic law enforcement efforts to counter biological threats. In the domestic arena, 

the FBI has taken lead responsibility for the operation of Joint Terrorism Task Forces (JTTFs)—

one in each of the 93 Federal judicial districts of the United States. These JTTFs are, in turn, 

coordinated through a National JTTF headquartered in Washington.33

The JTTFs serve a positive function coordinating efforts on a local or regional basis amongst the 

various law enforcement agencies with domestic responsibility. Typically, a JTTF will also have 

representatives from various other DHS and DOJ investigative offices such as Immigration and 

Customs Enforcement and Secret Service from DHS or the Drug Enforcement Agency from 

DOJ. They will also incorporate State and local law enforcement officials from the major urban 

areas within the domain of the JTTF (e.g., the Chicago Police Department and the Cook County 

Sheriff’s Office). Working through the National JTTF, the local and regional JTTFs have access 

to intelligence and analysis through the FBI’s participation in the National Counterterrorism 

Center (NCTC).34 Overall, this system appears to be reasonably effective, notably in getting 

intelligence to State and local officials not formally considered part of the IC. 

The problem, however, is one of focus and attention rather than structure. JTTFs are, properly, 

concerned with all forms of potential terrorist activity. This encompasses acts ranging from 

violent kinetic terrorism to nuclear threats. Given the breadth and scope of the JTTFs’ domain in 

the domestic law enforcement context, investigations relating to biological threats risk being 

given inadequate attention and resources. The contrast with how domestic law enforcement 

investigates cyber threats is instructive. To provide a unified focal point for cyber investigations, 

the DOJ has chartered a threat-specific task force, the National Cyber Investigative Joint Task 

Force, tasked with coordinating cyber-related terrorism investigations throughout the United 

States.35 No comparable task force exists for biological threats. 

11

                                                           

32 Department of State policy, for example, requires embassy clearance for any official travel to a foreign country. 

See 22 U.S.C. § 3927 and E.O. 10893, Part II (establishing country authority of Ambassadors and Chiefs of 

Mission). Other regulations, 22 C.F.R. §181.4, require any formal agreements with a foreign country to be approved 

by the Secretary of State.

33 The authority for the FBI to lead in the coordination of domestic law enforcement counter-terrorism efforts is 

found in 28 U.S.C. §553; 28 CFR §0.85 and NSPD 46/HSPD 15. In recognition of the coordination efforts of 

JTTFs, the Deputy Chief of the National JTTF is a supervisory agent from the Immigration and Customs 

Enforcement (ICE) component of DHS.

34 The operational arms of the intelligence community and the military are, generally, prohibited from participating 

in domestic investigations and, therefore, pose little coordination concern in this arena . See 50 U.S.C. §403-

4a(d)(1)(CIA’s has “no police, subpoena, or law enforcement powers or internal security functions”); 18 U.S.C. 

§1385 (prohibiting military from exercising law enforcement or peace officer powers). 35 In addition, both the FBI and the Secret Service have purpose-dedicated cyber crime investigative divisions. To be 

fair, the prevalence of cyber crime (principally fraud and identify theft) assuredly warrants the devotion of greater 

resources to cyber issues on a day-to-day basis. But the similarities between the two types of threats (their diffuse 
Threat Reduction and Detection/Surveillance—An entirely different set of fragmentation and 

coordination issues arises when our focus turns from challenges related to counter-terrorism, 

intelligence, and law enforcement to areas of cooperative threat reduction and biological threat 

surveillance. 

Threat Reduction—In addition to the counterterrorism/intelligence activities aimed at 

detecting and interdicting biological threats, there are, in theory, two other components to any 

program to reduce the threat of a biological attack: limiting access to source materials and 

technology and reducing the spread of technical know-how. In practice, both of these tactics are 

exceedingly difficult, but not impossible, to implement. 

The types of tactics that might, theoretically, be used to reduce the likelihood of a biological 

attack range from modest activities intended to enhance situational awareness, such as a simple 

census of the location of sensitive technologies or pathogens, to more aggressive efforts to 

require those working with certain materials to register their activities. Today, there is no such 

requirement, though there is a professional code of best practices that researchers often follow. 

Good policy might consider making some requirements mandatory as they are today for aspects 

of human subject research and research animal treatment. 36

 Beyond situational awareness, threat reduction efforts could seek to deny problematic actors 

supplies of critical pathogens by restricting access to sources of origin, to the laboratories in 

which the pathogens are located, or to the equipment with which pathogens might be 

manipulated. Perhaps most controversially, these efforts might even seek to limit the spread of 

biological knowledge by monitoring the activities of individual life scientists and/or preventing 

certain individuals from participating in the biosciences.37 Such a policy is inimical to the 

practice of modern science, in which collaboration is the norm. In addition, a counter argument 

notes that, by making the knowledge ubiquitous, the scientific community would be more likely 

to be self-policing. That is, anomalous research activities would be more likely to be noticed and 

reported. 

Needless to say, some of these threat reduction activities are highly controversial. Most have not 

been implemented yet and those that have been begun are in their infancy. Some, such as 

restricting access to bioscience learning, are unlikely ever to be adopted. Others, such as limiting 

access to equipment, are most certainly fruitless since that equipment is freely available in the 

global market. And, given the dual use nature of all biological research activity, any effort at 

12

                                                                                                                                                                                               

nature, difficulties of attribution, and international character) suggest that a similar organizational model (albeit with 

fewer resources) might be appropriate in the biological threat domain.

36 CDC, “Biosafety in Microbiological and Biomedical Laboratories (5th Ed. 2009) [available at 

http://www.cdc.gov/biosafety/publications/bmbl5/BMBL.pdf]. 37 By way of example, one recent news report focused on the limited security provided by Ugandan laboratories to 

the anthrax stored at their facilities and the challenges faced by the United States in assisting Uganda in upgrading 

that security. Josh Kron, “Uganda Seen as a Front Line in the Bioterrorism Fight,” The New York Times, November 

10, 2010, accessed at http://www.nytimes.com/2010/11/11/world/africa/11uganda.html.
threat reduction must be careful not to collaterally diminish the potential for positive biological 

advances. 

In short, the threat reduction problem is a complex one and achieving results will require 

coordination both domestically and internationally. Within the Federal government, the 

coordination of efforts to address international biological threats is spread amongst a host of 

agencies and programs. Some of the more prominent ones (and this is not a comprehensive list) 

include: 

• The Biological Threat Reduction Program managed by DOD with the cooperation of 

HHS and the Department of Agriculture (USDA), works to help upgrade bio-facilities 

and training overseas; 

• The Bio-Industry Initiative at the Department of State, targeted at transforming biological 

facilities in the former Soviet Union; 

• The Bio Security Engagement Program, also at the Department of State (a broad-based 

program in cooperation with international agencies to foster bio-safety training and 

surveillance worldwide) that operates in conjunction with the International Biological 

Threat Reduction Program at Sandia National Labs. 

Domestically, HHS/CDC and USDA run pathogen registry programs collectively known as the 

National Select Agents Registry (NSAR) Program. The NSAR catalogs and manages the 

possession of biological agents and toxins that have the potential to pose a severe threat to 

public, animal or plant health, or to animal or plant products. Under the NSAR, facilities 

including government agencies, universities, research institutions, and commercial entities that 

possess, use or transfer the identified biological agents and toxins are required to register with 

the government. To the extent that new threats, whether naturally occurring or man-caused, are 

identified, the National Institutes of Health (NIH) will be responsible for coordinating with the 

private sector to develop new vaccines for possible distribution. 

More recently, President Obama has directed HHS and USDA to begin a process of prioritizing 

the identified select agents and providing enhanced security measures for those that pose a 

greater risk. Those standards will include “practices to ensure reliability of personnel with 

access” to the new, Tier 1, select agents, and the “establishment of physical and cyber security 

practices for” Tier 1 facilities.38 Emblematic of the coordination problem, more than two dozen 

agencies and offices within the Federal government will participate in the process of designation 

and in the development of the new standards. 

Surveillance and Diagnosis -- Unlike most other events, a biological attack could occur 

without anyone realizing it had happened. It is perfectly plausible to imagine scenarios where 

victims are infected without their knowledge and do not develop symptoms for many days. Thus, 

13

                                                           

38 “Executive Order 13546, “Optimizing the Security of Biological Select Agents and Toxins in the United States,” 

75 Fed. Reg. 39439 (July 8, 2010) [available at http://edocket.access.gpo.gov/2010/pdf/2010-16864.pdf]. 
a biological attack may, at first, be confused with the outbreak of a naturally-occurring disease. 

National security and public health officials must not only identify an illness that has occurred, 

but also determine whether it is of natural or man-made origin. This makes the development of 

surveillance techniques critical -- the sooner an attack is identified and its nature determined, the 

sooner countermeasures can be developed and deployed and infected individuals can be 

treated.39

To achieve early detection within the United States, the Federal government has adopted a varied 

series of detection and diagnostic approaches, including environmental detection, syndromic 

surveillance, and information sharing. These programs include the deployment of the BioWatch 

program, the development of the Biological Warning and Incident Characterization System, the 

establishment of the National Biosurveillance Integration Center (all through DHS), the 

establishment of the BioSense Program through the Centers for Disease Control and Prevention 

(CDC), and the expansion of the Electronic Surveillance System for Early Notification of 

Community-based Epidemics, or ESSENCE, program in the DOD. 

These efforts are intended to address a wide range of potential biological threat events, from 

large-scale releases of biological agents to small-scale releases that affect a smaller area or fewer 

people. Domestically, these efforts must be undertaken in collaboration with State and local 

jurisdictions whose health professionals will often be the first to identify outbreaks. The efforts 

must also include coordination with the private sector—the hospitals where infected individuals 

will present themselves for treatment and the network of public health laboratories responsible 

for handling and analyzing the clinical samples related to potential bioterrorism events. Thus, 

beyond the several Federal agencies with surveillance and diagnosis responsibilities, there are 

literally hundreds of other State and local organizations that are also involved as well as an 

unspecified number of private sector organizations. 

When the focus turns from domestic detection and diagnosis to overseas detection, the problems 

of coordination become even more complex and daunting. The Federal government has invested 

in a number of global health activities partly in order to help identify when an emerging disease 

might pose a threat to the United States.40 Most notably, the CDC’s Global Disease Detection 

(GDD) efforts aim to “protect the health of Americans and the global community by developing 

and strengthening public health capacity to rapidly detect and respond to emerging infectious 

diseases and bioterrorist threats.”41

14

                                                           

39 In general, earlier treatment increases the likelihood of survival and recovery and reduces the likelihood of 

casualties or fatalities. L.M. Wein, D.L. Craft, and E.H. Kaplan, Emergency Response to an Anthrax Attack, Proc. 

Natl. Acad. Sci., 100(7), 2003, 4346– 51. 40 See CRS Report R40239, Centers for Disease Control and Prevention Global Health Programs: 

FY2001-FY2011 (2010). 41 CDC, Global Disease Detection, Policy Paper, June 2008, [available at 

http://www.cdc.gov/cogh/pdf/GDD_At_a_Glance_2008.pdf].
CDC’s efforts are, naturally, coordinated with both the Department of State and the World Heath 

Organization (WHO). There are seven GDD centers in China, Egypt, Guatemala, India, 

Kazakhstan, Kenya, and Thailand. During health emergencies, such as the emergence of 

pandemic flu in 2009, the CDC can use the centers for bilateral response or as part of the Global 

Outbreak Alert and Response Network (GOARN), which is coordinated by WHO.42 

 The Judiciary -- The Nation’s judiciary represents a key target for terrorists for two 

reasons. First, legal decisions regarding jurisdiction, criminal intent and the parameters within 

which local and Federal officials and responders could operate will be affected by the courts, and 

thus disruption of the judicial system could be catastrophic. Second, the legal system and courts 

are important symbolic targets, a characteristic that has been very attractive to terrorist 

organizations such as al Qaida. The courts are relatively “soft” targets, being high-traffic areas 

largely open to the public. For example, the Court of Appeals in Washington, DC. is visited by 

more than 7,000 people per day. In the event of a biological incident, judges will be confronted 

with many decisions, some with scant legal precedence or precedence largely irrelevant to the 

prevailing conditions. Some examples include whether or not a suspected perpetrator can be 

coerced into providing bodily samples for diagnosis, the question of the legality of quarantines, 

and the rights of defendants as either criminals or illegal combatants, to name just a few. In 

extreme situations with a large number of affected people, decisions regarding distribution of 

limited stockpiles of medical supplies may also be required. Therefore, it is imperative that 

contingency plans be made to keep the judicial system functioning. 

It is equally important that judges be trained a priori to address these issues, which will differ in 

situations where a disease outbreak is naturally occurring versus where it is intentionally caused, 

and between outbreaks which target humans versus those that affect economic targets, such as 

livestock. One key DOJ program is the Advanced Science and Technology Adjudication 

Resource (ASTAR) program. ASTAR is a program that trains State and Federal high court 

judges in the basics of the key scientific issues of the day and certifies judges to adjudicate cases 

involving science and technology. While ASTAR is aimed at science writ large, it has 

components related to bioterrorism and medicine which are relevant to decisions which the 

judiciary may face during a biological incident. 

Military Activities-- Finally, our lack of biological threat coordination is notable in the lack of a 

strong coordinating structure within the military that would have responsibility for mobilizing 

military resources devoted to biological threat prevention, preparation and (in the event of 

failure) response. Once again, the contrast with the cyber domain is instructive. 

For cyberspace, the Secretary of Defense has created a new command, the U.S. Cyber 

Command, a sub-unified command subject to the authority of the commander of the U.S. 

                                                           

15

42 A summary of the GOARN program can be found at http://www.who.int/csr/outbreaknetwork/en/.
Strategic Command.43 Under the DOD Unified Command Plan, Cyber Command is tasked with 

securing American freedom of action in cyberspace and mitigating the risks to national security 

that come from dependence on cyberspace. It is, therefore, the home of both offensive and 

defensive military cyber missions of all sorts. 

There is no comparable institution in the military for biological threats, nor should there be. 

Cyber attacks are, rightly, perceived as having a higher threat level for American interests and a 

greater ongoing impact on the American economy. In addition, cyber issues pervade military 

command and control in a way that biological threats do not. It is, therefore, appropriate for 

DOD to have created a command devoted to exclusively to cyber warfare. 

No such command is needed for biological threats. But the military lacks any command structure 

or other strong coordination structure for biological events. While various commands have 

frequently conducted exercises in an effort to develop practical responses to potential biological 

events, those exercises are often necessarily regional in character – given that most combatant 

commands are regionally-based. To date, there exists no single center of excellence within 

DOD’s operational commands to which the military can readily turn for a comprehensive 

national approach (if one is ever needed). To be sure, the military scientists at Fort Detrick have 

significant expertise.44 But they conduct principally scientific research that is defensive in 

nature, focusing on diagnostics, preventives, and treatments for biological warfare infections. It 

is not an operational command. 

Indeed, if tomorrow a purposeful biological outbreak were to occur in the United States and the 

President were to ask the Secretary of Defense for support, the Secretary would not have any 

clarity in which DOD entity to task with providing an operational response. While on-going 

exercises and planning are being used to develop DOD doctrine for a response, that doctrine has 

yet to be fully resolved. Presumably, for an outbreak in the United States, the Secretary would 

turn to the Commanding General of the U.S. Northern Command (NORTHCOM), the unified 

command tasked with providing homeland defense, civil support and security cooperation to 

defend and secure the United States and its interests. However, NORTHCOM has not identified 

any particular units with the responsibility for planning and training for a biological response, 

but could draw on such activities as the U.S. Army’s 20th Support Command CBRNE (Chemical, 

Biological, Radiological, Nuclear, and High Yield Explosives) based at the Aberdeen Proving 

Grounds. 

16

                                                           

43 The new commander of USCC is dual-hatted and also serves as the Director of the NSA. A useful summary of the 

political considerations that led to this unusual result can be found in Richard A. Clarke & Robert K. Knake, Cyber 

War (Harper Collins 2010), 32–44. 44 Fort Detrick is the military’s center for biomedical research and development, medical material management, 

global medical communications and the study of foreign plant pathogens. It is home to the U.S. Army Medical

Research and Material Command (USAMRMC), with its bio-defense agency, the U.S. Army Medical Research 

Institute of Infectious Diseases (USAMRIID). In years past, it was also the home for the U.S. biological weapons 

program.
The closest we come to a dedicated unit with biological threat responsibility is the Fort Monroe, 

Va.-based Joint Task Force-Civil Support (JTF-CS). This small military unit is tasked with 

providing oversight of DOD Title 10 forces responding to a CBRNE incident. But to actually 

function, this JTF-CS must, in turn, draw from various military assets held by the four services. 

The problem is compounded by the poor state of readiness of those military assets. As a 2007 

GAO study concluded: “Most Army units tasked with providing chemical and biological defense 

support are not adequately staffed, equipped, or trained to perform their missions.”45 Indeed, the 

National Guard and Reserve units that would be particularly responsible for responding to 

biological or chemical incidents within the homeland “report[ed] low readiness ratings—in other 

words, they are not considered sufficiently qualified for deployment. The low readiness ratings 

reflect critical personnel shortages” in the units.46

In short, at the operational level, there are a significant number of largely-uncoordinated Federal 

agencies and sub-agency components that are engaged in biological threat prevention, threat 

reduction, event characterization, and surveillance and diagnosis. They are joined in that effort 

by international organizations and State, local and private-sector actors. The lack of a higherlevel coordinating function makes the unification of their efforts a daunting task. 

Table 1—Bio Threats: Prevent & Detection 

Within the US Outside the US–Allies Outside the US–

Non-Allied Nations 

and Non-State 

Actors 

Counter 

Terrorism 

FBI 

NCTC 

DHS 

FBI 

State 

CIA/DIA 

DHS 

DOD 

FBI 

ODNI 

NCTC/NCPC 

CIA/DIA/NSA 

DOD 

Threat Reduction DHS 

HHS/CDC/NIH 

State 

HHS/CDC/NIH 

FBI 

CIA 

                                                           

45 Chemical and Biological Defense: Management Actions Are Needed to Close the Gap between Army Chemical 

Unit Preparedness and Stated National Priorities, at 5 (GAO-07-43) [available at 

http://www.gao.gov/new.items/d07143.pdf]. 46 Ibid. 5-6.

17
Agriculture 

Private Sector 

Private Sector ODNI 

State 

DOD 

Surveillance & 

Diagnosis 

DHS 

Private Sector 

HHS/CDC 

Agriculture 

FBI 

DOD 

EPA 

State 

HHS/CDC 

Private Sector ÆÆ

World Health Organization 

ÆÆ

All of which is not, of course, to suggest that creation of a unified coordination structure for 

biological threats would be a panacea. It will not solve all of the military coordination issues, nor 

will a unified civilian command fully meld the DOJ(FBI)/DHS/ODNI/HHS efforts to prevent 

and detect a biological attack. It is important, however, to note that the confusion of roles at the 

highest levels of the Federal government has filtered down to operational units, leaving them 

poorly-coordinated and, in many instances, poorly -staffed and -trained. 

Going forward, we will need to take several steps to resolve these ambiguities. These include 

capitalizing on lessons learned from recent biological events like the H1N1 pandemic and the 

further development of coordinating structures based upon a more robust suite of 

Federal/State/local biological incident exercises. This is no easy task. It will take concerted 

leadership from the top to resolve these issues. 

III. Threshold Challenges: State to Federal Responsibility and the 

DHS/HHS Question 

A different way of characterizing plans for preparation and response to a biological event turns 

not on the functional activity to be undertaken, but on the source or origin of the biological 

outbreak. Indeed, that may be a critical determinant in Federal organization because roles and 

responsibilities are likely to vary widely based upon the character of the event, perhaps more so 

than based on the nature of the function. Certainly, it appears likely that the identification of 

18
leadership and coordination roles will turn on the character of the biological event, since it 

matters very much whether the event is the outbreak of a naturally-occurring disease or a 

biological attack. 

Civilian, non-national security agencies will predominate in response to naturally occurring 

events. Initially, there will be virtually no Federal involvement in the response. The Federal 

government will become engaged only when (as with the recent H1N1 outbreak47) the scope of 

the incident grows so significant that the response exceeds the capacity of State, local, and 

private sector responders. 

By contrast, DHS, DOJ and DOD will take a much earlier and far more active role when 

deliberate, terrorist action is suspected. Indeed, even the infection of a single individual will 

garner Federal attention if it is suspected that the infectious agent was deliberately introduced. Of 

equal significance, for a natural outbreak, the Federal responsibility will lie with our health 

agencies, principally coordinated by the Secretary of HHS, while the response to a suspected 

biological attack will likely be directed by the Secretary of Homeland Security. 

Hence, another taxonomy that bears on the discussion is: 

• Natural or Non-Malicious Outbreaks: Natural outbreaks would encompass events arising 

from the natural development and outbreak of an infectious disease, such as H1N1. Nonmalicious outbreaks, by contrast, might arise from accidental human action, for example, 

through an accidental release from a laboratory or the mistaken contamination of the food 

supply. 

• Biological Attack: Events arising from the deliberate introduction of a biological agent 

(whether by a nation-state or a non-state actor), including point source releases (e.g., a 

mall or a stadium), network releases (e.g., contamination of the postal system or a 

transportation hub), and aerosolized releases into the atmosphere. This will also include 

food and/or water system attacks, though those events concern not only human infection, 

but also contamination of the food or drinking water supply, and therefore pose 

somewhat different response challenges. 

The greatest challenge is that, at the outset, it will be exceedingly difficult to distinguish between 

a naturally-occurring and a purposeful incident.48 We may anticipate that all or almost all 

19

                                                           

47 In 2009, the outbreak of an H1N1 influenza pandemic led both the U.S. Government (through the CDC) and the 

World Health Organization to declare a public health emergency. The Federal government led a response that 

included vaccinations, communication and syndromic monitoring. See The 2009 H1N1 Pandemic: Summary 

Highlights, April 2009-April 2010 [available at http://www.cdc.gov/h1n1flu/cdcresponse.htm]. 48 To that end, the Federal government has undertaken a strategic initiative to enhance our bio-forensic capabilities. 

Under this initiative, we will develop a strategic microbial forensics research agenda that will produce a national 

microbial forensic capability that is ultimately capable of high confidence, robust detection, characterization and

comparison of biological agents in forensic samples. See “National Research and Development Strategy for 

Microbial Forensics,” (2009), 
deliberate biological attacks will initially appear to be nearly identical to the outbreak of a 

naturally-occurring disease, thus emergency room physicians cite a preclinical diagnostics 

capability as a top priority. As bio-forensics improve, the time period before an accurate 

characterization is achieved will diminish, but we cannot reasonably anticipate that it will ever 

be reduced to zero. This is a formula for significant confusion—if the transition of responsibility 

is dependent on the nature of the event, yet biological forensics are generally weak and cannot 

distinguish between the two circumstances, then the vital leadership transition point is left to 

guesswork and political will, rather than deliberate, fact-based analysis and clear, mutuallyagreed standards. More importantly, if we start with the assumption that a bio-event is naturally 

occurring, but it turns out to be intentional, critical response time may be lost, which may 

directly affect our ability to save lives.49

Of perhaps even greater concern, strategic planning for this transition of responsibility from the 

State and local first responders to the Federal government is relatively non-existent, while 

planning for the division of Federal responsibility is internally inconsistent. There is little, if any, 

effort to define when a transition from State or local responsibility to Federal responsibility 

would arise or when the HHS/DHS transition might occur. Indeed, as one observer has noted: 

“In fact, our situation is even worse than it would be if all we lacked was a 

strategy. In keeping with the long-standing division of responsibilities between 

the Federal and state governments, public health issues have been pretty much the 

exclusive province of state and local governments, each of which has been pretty 

much free to determine its own legal authorities, organizational structure and 

capability mix. That arrangement is almost certainly best when dealing with 

normal public health issues, but the suitability of our current mix of organizations 

and authorities for events which span state boundaries must be questioned. Just as 

public policy changes . . . may be necessary for responding to truly catastrophic 

oil spills, so too, public policy changes are almost certainly necessary if we are to 

be ready for a major biological event.”50

State To Federal Transition: One of the principal issues we will need to determine is when, 

during the course of a biological incident, authority and responsibility for leading the response 

                                                                                                                                                                                               

http://www.whitehouse.gov/files/documents/ostp/NSTC%20Reports/National%20MicroForensics%20R&DStrategy

%202009%20UNLIMITED%20DISTRIBUTION.pdf. Unfortunately, the time-line for the development of this 

capability is speculative, at best.

49 Though it is beyond scope of this monograph, completeness requires mention of the circumstance that State and 

local public health agencies have had to make serious financial cutbacks on their biodefense efforts because of tight 

fiscal circumstances. Since these public health agencies serve as the front line of defense in these types of incidents, 

a reduction in capability has a serious impact on biodefense. On details about reductions in spending at State and 

local levels see Trust for American’s Health, “Ready or Not?,” (2011), 15–17 ( 

http://healthyamericans.org/assets/files/TFAH2010ReadyorNot%20FINAL.pdf.

20

50 Bob Ross, Authority and Strategy—The Legal Foundation for Successful Emergency Response, at Biosecurity 

Blog, http://biosecurityblog.com/2010/09/20/authority-and-strategy-%e2%80%93-the-legal-foundation-forsuccessful-emergency-response/.
will transition from State and local to Federal authorities. Managing and defining this transition 

will be critically important operationally. To date, there exists no settled doctrine on how or 

when that transition is to occur. 

To be sure, there will be events (for example, the anthrax attack on Senate offices in 2001) where 

a Federal response will be immediate because the biological agents are accompanied by a selfdeclaration as to their provenance. Put another way, if Al Qaeda or any other terrorist 

organization conducts a biological attack and, contemporaneously, takes public credit for the 

attack, it is likely, as it was with the anthrax attacks in 2001, that the response will be 

immediately Federalized, and no issues of a “transition” will be presented. 

But an equally plausible scenario (indeed, perhaps a more plausible one) may involve the 

manifestation of a biological event that initially cannot be characterized as to source. When this 

sort of incident is initially addressed, the first response will come through the normal operation 

of State or local public health agencies. Federal involvement will come only when one of two 

factors arise: 1) the biological forensics establish that the incident is a deliberate attack and not a 

naturally-occurring outbreak; or 2) the scope of the outbreak (whether an attack or a natural 

event) becomes so great that it outstrips the capacity of State and local authorities to effectively 

respond. 

We need no new doctrine to address the first of these situations. When and if terrorist 

involvement becomes reasonably clear, the Federal government will assume responsibility for 

addressing the incident. But no clear doctrine exists for the other portion of the transition—when, 

if ever, will the Federal government assume responsibility for aspects of the medical response to 

a biological incident, stepping in to replace State and local authorities? 

Little has been done to prioritize various attack risks, nor has any significant effort been made to 

quantify the nature of what would constitute critical federal interests, requiring federal action. 

For example, the DHS National Infrastructure Protection Plan (NIPP) defines Tier 1 critical 

infrastructure as those infrastructure elements whose loss would equate to the effects of 

September 11 or Hurricane Katrina. The NIPP then prioritize them for protection from allhazard threats.51 

For any number of reasons, this threshold seems inadequate to the task of providing doctrine on 

the transition of responsibility. To begin with, needless to say, such an indefinite and innumerate 

threshold only invites disagreement and confusion. Absent a clear line of demarcation, a 

transition point simply becomes a muddle. 

Second, the NIPP, while nominally a national plan, is a DHS-generated document; no threshold 

will be of any utility until it is accepted universally by all Federal and State stakeholders as an 

21

                                                           

51 See Department of Homeland Security, National Infrastructure Protection Plan 41 (2009). Anecdotally, some in 

DHS use a rough numeric measure positing that Federal involvement would be likely when casualties exceed 10,000 

or economic losses exceed $10 billion. There is, of course, no formal doctrine adopting this metric.
appropriate definition for action. Absent collective “buy-in,” a DHS-defined threshold has 

limited authority and budget for implementation. 

More significantly, these nascent efforts to generate a threshold for Federal involvement, while 

salutary, are more readily suited for non-biological incidents than they are for biological ones 

under consideration here. A nuclear attack, for example, would be a single-point incident and 

readily susceptible to concrete measurement of casualties and economic effects within a confined 

geographic space. The same is true of natural disasters, such as a hurricane, or point-release 

chemical agents. 

Biological incidents, on the other hand, tend to be more diffuse and geographically widespread. 

Certainly naturally-occurring incidents cannot be expected to be geographically localized, 

though an attack might be more confined in space. Likewise, biological incidents are not 

confined in time to a single instance, but rather play out over a period of days or weeks. 

Thresholds, like the NIPP Tier 1 definition, that seem designed to address a single incident 

would have a tendency to miscalculate the need for Federal involvement in several ways: 

• Widely-dispersed naturally-occurring biological incidents might exceed the threshold of 

economic effects without straining any particular localities’ resources, making significant 

Federal involvement unnecessary; 

• Conversely, even modest incidents with little significant impact might – because of their 

salience – cause significant public fear and concern that require Federal involvement; 

• A threshold based on actual casualties (as opposed, say, to one based on the number of 

people who might seek treatment or testing) might understate the scope of the disruption. 

For these reasons, it seems likely that any threshold for transition from State or local to Federal 

responsibility will be different in kind from those associated with single-incident events. In any 

event, the complete absence of any generally-accepted threshold (for biological or any other 

WMD incident) precludes appropriate planning and budgeting. 

Federal Transitions: DHS and HHS: The coordination of preparations for and responses to a 

biological event is as complex (if not more complex a challenge) as the challenge of coordination 

of a Federal biological threat prevention and detection response. Threat reduction and detection 

involves the coordination of agencies that frequently conduct joint operations; though challenges 

exist, DOJ and DHS and DOD are all somewhat experienced at coordinating their activities with 

each other. 

By contrast, the development of a coordinated response in the wake of a biological incident 

(whether a naturally-occurring outbreak or a deliberate attack) will require the efforts of a host of 

Federal and State-level agencies that, in many cases, are unused to participating in a coordinated 

effort and, in the context of a terrorism event, certainly unused to participating in efforts that 

have law enforcement or national security consequences. 

22
As we’ve already noted, the coordination challenge begins with the necessity of engaging State 

and local first responders—police, emergency preparedness, and public health officials. In a 

significant incident, it will also include coordination with private sector actors such as hospitals, 

physicians, health-care equipment providers and pharmacological companies. 

At the Federal level, the response to a biological incident will, obviously, require efforts from 

HHS/CDC and DHS in providing emergency services ranging from health care to transportation. 

In cases of suspected terrorist activity, the FBI and DOJ will be tasked with conducting the 

domestic aspects of the investigation, while State, the CIA and the ODNI would work on the 

international aspects of attribution. Meanwhile DOD will, in many circumstances, be obliged to 

provide support and technical assistance to civil authorities52 and even agencies as diverse as 

National Oceanic and Atmospheric Administration (NOAA), which has expertise in air plume 

modeling that may be of use in response to an aerosolized release of a biological agent, and 

Department of Energy, which has expertise in an array of biological and chemical detection 

methodologies, may be called upon. 

To see the complexity of the requirements for coordination, consider the scenario of an 

aerosolized anthrax attack.53 The functional mission areas that will need to be engaged in 

response to such an attack, and the relevant agencies that would be required to assist in the effort, 

include: 

• Prevention/Deterrence—DOD; CIA; ODNI; HHS/CDC; DHS; DOJ/FBI; State; USDA 

• Emergency Assessment/Diagnosis– HHS/CDC; DHS; DOJ/FBI; NOAA; EPA; 

State/Local 

• Emergency Management/Response– DHS; HHS/CDC; DOD; State/Local; Private Sector 

resources54

• Hazard Mitigation—HHS/CDC; DHS; EPA; DOT; State/Local 

• Evacuation/Shelter—DHS; DOD; State/Local; Private Sector55 

23

                                                           

52 This support to civil authorities will be provided consistent with existing military doctrine. DOD Directive 

5111.13 (March 2009) defines Defense Support to Civil Authorities (DSCA) as: “Support provided by U.S. Federal 

military forces, National Guard forces performing duty in accordance with [Title 32, U.S. Code], DOD civilians, 

DOD contract personnel, and DOD component assets, in response to requests for assistance from civil authorities for 

special events, domestic emergencies, designated law enforcement support, and other domestic activities. Support 

provided by National Guard forces performing duty in accordance with [Title 32, U.S. Code] is considered DSCA, 

but is conducted as a State-directed action. Also known as civil support.” 

53 An aerosolized anthrax attack is one of the 15 National Planning Scenarios that form the framework for most 

Federal emergency response planning. The summary here is based upon the National Planning Scenario Executive 

Summary (April 2005) (available at http://cees.tamiu.edu/covertheborder/TOOLS/NationalPlanningSen.pdf), 54 Under the National Response Framework, private sector resources for emergency responses are mobilized through 

various sector- and function-specific coordinating programs, known as the Emergency Support Functions, or ESFs. 

National Response Framework, (2009) 29, http://www.fema.gov/pdf/emergency/nrf/nrf-core.pdf. 55 In addition the Occupational Safety and Health Administration and the National Institute of Occupational Safety 

and Health (a part of CDC) will participate in the setting of safety standards for any sheltering activity. Meanwhile, 

particular institutions like the Office of Personnel Management and Congress will be responsible for significant 

evacuation actions aimed at maintaining the continuity of governmental operations. 
• Victim Care—HHS/CDC/FDA; DOD; USDA; State/Local; Private Sector 

• Investigation/Apprehension—DOJ/FBI; ODNI/CIA; USDA; State; DHS; State/Local law 

enforcement; HHS/CDC; DOD 

• Recovery/Remediation—EPA; HHS/CDC; DHS/FEMA; State/Local; Private Sector 

Despite the clear need for a strong coordination function within the Federal government, the 

foundational documents regarding such coordination authority reflect some confusion and 

dissonance. As the Government Accounting Office (GAO) reported last year: 

“Federal government leadership roles and responsibilities for pandemic 

preparedness and response are evolving, and will require further testing before the 

relationships among the many federal leadership positions are well understood. . . 

. . [I]t is not clear how these would work in practice. According to the National 

Pandemic Strategy and Plan, the Secretary of Health and Human Services is to 

lead the federal medical response to a pandemic, and the Secretary of Homeland 

Security will lead the overall domestic incident management and federal 

coordination. In addition, under the Post-Katrina Emergency Management 

Reform Act of 2006, the Administrator of the Federal Emergency Management 

Agency (FEMA) was designated as the principal domestic emergency 

management advisor to the President, the HSC, and the Secretary of Homeland 

Security, adding further complexity to the leadership structure in the case of a 

pandemic. . . . [T]he relationship of these roles to each other as well as with other 

leadership roles in a pandemic is unclear.”56

This is, candidly, a bit of an understatement. To cite but one example, the GAO has, in another 

report, remarked upon the fact that no agency of the Federal government bears responsibility for 

monitoring the extent to which State and local public health agencies or private sector health 

providers are prepared for their role in implementing a national response to the outbreak of a 

pandemic disease.57 Given that these stakeholders are expected to play a vital role in any 

national response, the lack of any mechanism for Federal accountability is striking. 

The situation grows somewhat more confused when the pandemic outbreak is the product of a 

deliberate attack of some form. The Biological Incident Annex to the National Response 

Framework designates HHS as the “coordinating agency for all biological incidents, including 

those that are terrorist in nature.” 58 By contrast, the Catastrophic Incident Annex designates 

DHS/FEMA as the coordinating agency for all catastrophic incidents and defines “catastrophic” 

as “any natural or manmade incident, including terrorism, that results in extraordinary levels of 

24

                                                           

56 GAO, Influenza Pandemic: Gaps in Pandemic Planning and Preparedness Need to Be Addressed (GAO-09-909-

T, July 2009).

57 GAO, Influenza Pandemic: Monitoring and Assessing the Status of the National Pandemic Implementation Plan 

Needs Improvement, (GAO-10-73, Nov. 2009) 10–12. 58 “Biological Incident Annex,” http://www.fema.gov/pdf/emergency/nrf/nrf_BiologicalIncidentAnnex.pdf.
mass casualties, damage, or disruption severely affecting the population, infrastructure, 

environment, economy, national morale, and/or government functions.” 59 Plainly, at least some 

biological incidents might be catastrophic in nature. 

Yet anecdotal evidence, including discussions with current and former DHS and HHS officials, 

suggests that there is no agreement on this point. DHS officials believe that at some point a 

transition to a DHS-lead is contemplated by the existing directives—particularly in situations 

where a terrorist incident is suspected. By contrast, HHS officials are of the view that no 

transition is either expected or required, whether the incident is a natural outbreak or man-made 

in origin. Should such an incident occur, the conflict between the two agencies as to who would 

have lead authority would be unseemly, at best. At worst, such conflicts could hinder timely and 

appropriate response and thus exacerbate fatalities and economic damage. 

Here too, the multitude of agencies and the disaggregation of responsibility may be depicted in a 

simple chart. As this chart reflects, we lack an effective doctrine for determining vital command 

and control issues. 

25

                                                           

59 “Catastrophic Incident Annex,” http://www.fema.gov/pdf/emergency/nrf/nrf_CatastrophicIncidentAnnex.pdf.
Table 2—Bio Threats: Prepare and Respond 

 State/Federal Transition HHS/DHS Transition (?) 

Routine Scale Non 

Catastrophic–

Supportive 

Major 

Disruption 

Catastrophic–

Major Injection 

Natural 

Outbreak 

S/L Public 

Health 

HHS 

USDA 

HHS 

USDA 

State/Local 

DHS (?) 

HHS lead 

DHS supportive 

HHS lead (?) 

Biological 

Attack 

S/L Public 

Health 

S/L Hazmat 

HHS 

EPA ÆÆ

FBI-WMD ÆÆ

HHS 

NCTC ÆÆ

DHS ÆÆ

DOT (mode) 

USDA 

(food/water) 

HHS lead (under 

Bio-Incident 

Annex) 

DHS 

(supportive) 

FBI 

ODNI/CIA 

DHS lead (under 

Catastrophic 

Incident Annex) 

(?) 

HHS (supportive) 

FBI 

ODNI/CIA 

IV. Recommendations

Improved Federal Coordination: The current Administration has, through the appointment of a 

WMD coordinator, made an effort to address the lack of cross-government coordination for the 

detection and prevention of biological threats. But, as the foregoing review makes clear, there 

continues to be confusion and an overlap of responsibilities. The dry recitation of facts masks a 

traditional Washington concern—a battle over turf and budgets—and makes clear that more 

effort is required 

No organizational plan is likely to succeed if a single Federal agency is given a comprehensive 

lead responsibility. One would expect that sensitivities and legislative barriers are too great to 

26
ever permit, for example, DHS to be made responsible – and funded -- for coordinating all 

biological threat responses. What is required is decisive leadership from the White House to 

resolve the current confusion and provide a focal point for public sector coordination. 

This is easier said than done. Precisely the same arguments were made in support of the creation 

of the ODNI and DHS. In both cases a central focal point was thought necessary to achieve 

effective coordination of executive branch action. Both efforts may fairly be characterized as 

“ongoing works in progress” whose ultimate efficacy has yet to be conclusively determined. And 

just as the subordinated agencies have resisted inclusion within ODNI or DHS, it is likely 

(indeed nearly certain) that HHS and DHS would resist the strengthening of any White House or 

other centralized control of biological threat issues. 

If this logjam is to be broken, a new biological threat coordinator must, in effect, become the de 

jure leader of the Federal effort.60 This will require a strong commitment from the White House 

and the creation of a single, dedicated locus empowered and funded to coordinate the response to 

biological threats. It will be necessary to give the coordinator authority to: 

• Create a unified biological threats and security budget account within the President’s 

annual budget submission and work with the Office of Management and Budget and the 

NSC to set budget priorities with that account; 

• Lead and coordinate the development of biological threat policy (including through 

chairmanship of a dedicated policy planning group); 

• Direct agency action in conformance with the budgetary and policy priorities set; 

• Have indirect and consultative authority over, and a role in the selection of, cabinet-level 

and sub-cabinet leaders in the agencies and their components which deal with biological 

threat issues; and 

• Lead a process to develop a comprehensive set of objectives derived from the National 

Biostrategy that will contain a set of measurable performance goals and objectives for 

biological threat reduction and resilience. 

To achieve this level of coordination and secure the cooperation of other Federal agencies, it is 

almost certain that the coordinator will need to have cabinet-rank and report directly to the 

President. Any lesser degree of empowerment will foreclose any realistic possibility of success. 

In short, if it wishes to advance the coordination function in a meaningful way, the White House 

must take ownership of the biological threat issue and endow the coordinator position with the 

authority necessary to achieve a set of clearly-defined and -articulated goals. 

27

                                                           

60 In a real crisis today, it is likely that operational control would be provided by the President acting through his 

national security advisors with implementation being supervised by the Secretaries of Homeland Security and 

Health and Human Services. To the extent this structure has become the anticipated de facto norm, it would be 

prudent to institutionalize it. To the extent it has not, clarification would be most appropriate. 
Finally, it is worth acknowledging that we should not be completely sanguine at the prospects for 

success in achieving this sort of restructuring. In addition to opposition from agencies whose 

roles and responsibilities will be modified, we should anticipate significant opposition from the 

Congress, State and local authorities, and the private sector whose activities would be regulated 

by such a coordinator. Congressional inertia and interest in protecting jurisdictional prerogatives 

is widespread; State and local officials are loath to accept Federal direction (even while asking 

for Federal resources; and the private sector is resistant to any activity that empowers 

governmental oversight. Coordinated budgeting will require the cooperation of the 

Appropriations Committees in both houses of the Congress in consolidating their consideration 

of the President’s budget request. Changes to various legislation setting the roles and 

responsibilities of Federal agencies as well as the Federal government’s authority and obligations 

to State and local governments will require support from an even broader range of committees. 

To the extent that legislative enactments are required to achieve centralizing objectives, their 

passage will require a significant investment of Presidential political capital. 

Develop a Clear Doctrine For Transitioning Authority As a Biological Incident Develops: No 

coordinating system can work if the lines of authority are not carefully drawn. The only thing 

worse than having nobody in charge is having more than one person in charge or, worse yet, 

several people disagreeing as to who bears responsibility. 

Of course, within the Federal government, the President will have the ultimate responsibility for 

coordinating any Federal response. To that end, if a strong national biological threat coordinator 

is appointed, that same coordinator would serve well as the individual with operational control 

over any coordinated Federal response. 

Such a strong, centralized, operational role for the White House is unlikely to materialize any 

time soon, since virtually all of the assets available to the Federal government for use in a 

response action will be deployed by one of the constituent agencies, which will likely resist any 

centralizing effort. Moreover, even if a centralized authority for the Federal government were 

capable of being created, we would continue to have much the same problem we do today in 

response to any natural disaster—even a strong Federal leader has difficulty coordinating the 

activities of State, local and private sector stakeholders. 

Thus, for the foreseeable future, the most realistic expectation is for a set of clear lines of 

authority and specific demarcation points to mark the transitions of authority within the response 

structures. We need clear doctrine to define the thresholds for: a) the transition from State to 

Federal level responsibility; and b) the transition (if any) within the Federal government from 

HHS-led to DHS-led responsibility. 

As an urgent matter, the Federal government should sponsor an internal study of this matter with 

the goal of defining U.S. doctrine for those transition thresholds. The key characteristics of 

success for such a doctrine would be clarity and resolution in defining the thresholds. As noted 

28
above, the transition points identified must be selected with the unique aspects of biological 

threats (e.g., geographic dispersal; time-delayed detection; and public fear) in mind. 

That having been said, the following is offered as a rough approximation of a set of thresholds 

that make some logical sense (assuming, for now, that any threshold unit developed for a singleincident event is appropriately generalized to the biological response arena), and which (if 

adopted) would provide the necessary clarity: 

• State to Federal Transition 

o Authority for coordination of medical response activities transitions when: 

 A state requests Federal assistance; or 

 Casualties exceed 10,000; or 

 Economic effects exceed $10 Billion; or 

 The President so directs (most likely in situations where a delay to allow 

State and local responses to occur first is judged to create a risk). 

o Authority for investigation of the causes of the outbreak transitions when: 

 Actionable forensic evidence is developed indicating that the outbreak was 

caused by deliberate human action; or 

 A State requests Federal assistance; 

 The President so directs. 

• Federal Transition—HHS to DHS 

o Authority for coordinating the medical response activities of the Federal 

government transition when: 

 The President so directs. 

o Authority for coordinating the non-medical response activities in response to the 

outbreak transitions when: 

 Actionable forensic evidence is developed indicating that the outbreak was 

caused by deliberate human action; or 

 The President so directs. 

If these thresholds, or any similar set of thresholds, were to be developed and adopted as an 

affirmative statement of national policy, many of the transition challenges identified would be 

alleviated. 

Develop a More Robust and Comprehensive Planning and Exercise Program for Biological 

Threats: To a very real degree the two theoretical problems outlined above (lack of a Federal 

coordinating structure and lack of a good sense of authority transition points) are grounded in the 

practical on-the-ground application of doctrine to reality. Our Federal bureaucracy is a complex 

organization in which the interagency battle over turf and budgets gets in the way of progress. 

Leadership is required at the highest levels to achieve the goal of an effective response to a 

biological or other weapon of mass destruction incident. 

29
30

We have (thankfully) little practical experience from which to derive lessons on how to deal with 

a biological incident. Save for the H1N1 pandemic, we have no recent comprehensive national 

experience relating to the challenges of Federal coordination and the inter-governmental transfer 

of authority. Specific threshold measures we might use to gauge our response are, at best, 

educated guesses and at worse, conjecture. We need to make an effort to establish better ex ante

rules to govern in a time of crisis, but have inadequate data to do so. 

This suggests the final recommendation. The necessary experience can be gained by exercising 

response plans in which principals and their advisors at the Federal, State, and local government 

levels participate, and then by reviewing the results of those exercises for lessons learned and 

gaps identified. As a matter of some urgency, we may best address the leadership challenges 

presented by biological threats through the development of a more robust and comprehensive set 

of exercises and planning efforts that will afford us the requisite experience base to guide our 

future doctrine.