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Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and Target Program Investments (Letter Report, 04/09/98, GAO/NSIAD-98-74).

Pursuant to a congressional request, GAO reviewed the implementation of
the Nunn-Lugar-Domenici (NLD) domestic preparedness program, focusing
on: (1) threat and risk assessment approaches used by several public and
private sector organizations to deal with terrorist and other security
risks; (2) whether 11 of the first 27 cities selected for NLD training
and assistance used threat and risk assessments to establish
requirements for dealing with weapons of mass destruction (WMD)
terrorist incidents; and (3) the challenges of using formal threat and
risk assessments to help define requirements and prioritize and target
NLD program resources.

GAO noted that: (1) it identified several public and private-sector
organizations that use threat and risk assessments to manage risk and to
identify and prioritize their security requirements and expenditures to
protect facilities, operations, equipment, and material against
terrorist and other threats; (2) for example, one company adapted U.S.
government threat and risk assessment standards and successfully applied
them to more than 19 of its overseas operations; (3) the company's risk
assessment approach involves a multidisciplinary team of experts that
uses valid threat information, to make judgments about the likelihood
and consequences of an asset being seized or destroyed, the asset's
criticality, and the asset's vulnerability to various threats; (4) the
company has applied its risk assessment process in a number of areas,
from its operations and facilities in Chad to its hiring practices; (5)
the NLD program is in the early stage of implementation, and most cities
have not yet received training, assistance, or equipment; (6) at the
time of GAO's review, threat and risk assessments were not performed by
either the cities or the NLD federal program agencies for 11 of the
first 27 cities selected for assistance; (7) if properly applied, threat
and risk assessments can provide an analytically sound basis for
building programmatic responses to various identified threats, including
terrorism; (8) although threat and risk assessments are not required in
the NLD program, they could help cities prioritize their investments in
WMD preparedness; (9) because the program is in the early stages of
implementation, opportunities exist to make program adjustments that can
help target NLD and other similar programs' training and equipment
investments; (10) GAO identified the following challenges to applying an
accepted threat and risk assessment process to cities selected to
participate in the NLD program: (a) security issues related to providing
valid threat data from the intelligence community to city officials; (b)
the lack of specificity in the intelligence community's threat
information; and (c) the complexity and magnitude of a large city as a
subject of a threat and risk assessment; and (11) these challenges could
be overcome through federal-city collaboration.

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

 REPORTNUM:  NSIAD-98-74
     TITLE:  Combating Terrorism: Threat and Risk Assessments Can Help 
             Prioritize and Target Program Investments
      DATE:  04/09/98
   SUBJECT:  Terrorism
             Emergency preparedness
             Domestic intelligence
             Prioritizing
             Explosives
             Military facilities
             Facility security
             Technical assistance
IDENTIFIER:  Nunn-Lugar-Domenici Domestic Preparedness Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

April 1998

COMBATING TERRORISM - THREAT AND
RISK ASSESSMENTS CAN HELP
PRIORITIZE AND TARGET PROGRAM
INVESTMENTS

GAO/NSIAD-98-74

Combating Terrorism

(701125) (701129)


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

  DOD - Department of Defense
  DOE - Department of Energy
  FAA - Federal Aviation Administration
  FBI - Federal Bureau of Investigation
  NLD - Nunn-Lugar-Domenici
  WMD - Weapons of Mass Destruction

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


B-279003

April 9, 1998

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

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

The Defense Against Weapons of Mass Destruction Act of 1996
established the Nunn-Lugar-Domenici (NLD) domestic preparedness
program.\1 The program is intended to enhance federal, state, and
local emergency response capabilities to deal with a domestic
terrorist incident involving weapons of mass destruction (WMD).\2
Congress established the NLD program in response to a perceived
significant and growing threat of WMD terrorism directed against
American cities and shortfalls in U.S.  cities' WMD emergency
response capabilities.  With its $30.5 million budget for fiscal year
1997, program initiatives planned or underway include develop and
execute a curriculum for training emergency response personnel in 120
cities selected for the NLD program; provide NLD cities some training
equipment (generally $300,000 worth of equipment per city), much of
which has operational capabilities;\3 and create a database on
chemical and biological agents.  The first 27 cities that were
selected for the NLD program are in the process of receiving
training.\4

As requested, we are reviewing the implementation of the NLD program. 
Our review includes an assessment of the program's status and
progress, the criteria and methodology used to select cities that
receive assistance, the approach used to determine the capabilities
and needs of participating cities, and the potential cost of
equipping a city to respond to a terrorist incident involving a WMD. 
As part of that effort, we explored how some public and private
sector organizations establish requirements and prioritize and
allocate resources to safeguard assets against a variety of threats,
including terrorism.  Specifically, we (1) examined threat and risk
assessment approaches used by several public and private sector
organizations to deal with terrorist and other security risks and
obtained detailed information on a private company's risk-assessment
process, (2) determined whether 11 of the first 27 cities selected
for NLD training and assistance used threat and risk assessments to
establish requirements for dealing with WMD terrorist incidents, and
(3) assessed the challenges of using formal threat and risk
assessments to help define requirements and prioritize and target NLD
program resources.  This report discusses an opportunity to enhance
decisions on how to allocate NLD and other similar federally funded
program resources.  We will report later on the rest of the work. 


--------------------
\1 The Defense Against Weapons of Mass Destruction Act was contained
in the National Defense Authorization Act for Fiscal Year 1997 (title
XIV of P.L.  104-201, Sept.  23, 1996) and is commonly referred to by
its sponsors' names, Senators Nunn, Lugar, and Domenici. 

\2 In the National Defense Authorization Act for Fiscal Year 1997
(section 1403), WMD are defined as any weapon or device that is
intended, or has the capability, to cause death or serious bodily
injury to a significant number of people through the release of toxic
or poisonous chemicals or their precursors, a disease organism, or
radiation or radioactivity. 

\3 The Department of Health and Human Services and the Federal Bureau
of Investigation have separately funded programs to purchase
equipment for U.S.  cities' emergency response personnel. 

\4 At the time of our review, 11 cities had received emergency
response training. 


   BACKGROUND
------------------------------------------------------------ Letter :1

The Department of Defense (DOD) is lead federal agency for
implementing the NLD program.  In that role, DOD works in cooperation
with the Federal Bureau of Investigation (FBI), the Department of
Energy (DOE), the Environmental Protection Agency, the Department of
Health and Human Services, and the Federal Emergency Management
Agency.  Before providing cities training and other assistance, a
federal interagency group comprising representatives from these six
agencies formulated and distributed information and questions to help
NLD cities assess their training and equipment needs.  Some of the
cities have begun to buy equipment for dealing with chemical and
biological terrorist incidents with federal and their own funds.  NLD
program officials have reported that local emergency response
personnel do not have the equipment and supplies necessary to protect
themselves and victims in a WMD incident, and that most cities would
be unable to afford them without federal assistance.  Further, in its
October 1997 report, the President's Commission on Critical
Infrastructure Protection\5 recommended that NLD funding be doubled
in fiscal year 1999 to, among other things, provide cities with
equipment to detect and identify WMD. 

Threat and risk assessments are widely recognized as valid decision
support tools to establish and prioritize security program
requirements.  A threat analysis, the first step in determining risk,
identifies and evaluates each threat on the basis of various factors,
such as its capability and intent to attack an asset, the likelihood
of a successful attack, and its lethality.  Risk management is the
deliberate process of understanding "risk"--the likelihood that a
threat will harm an asset with some severity of consequences--and
deciding on and implementing actions to reduce it.  Risk management
principles acknowledge that (1) while risk generally cannot be
eliminated, it can be reduced by enhancing protection from validated
and credible threats; (2) although many threats are possible, some
are more likely to occur than others; and (3) all assets are not
equally critical.  Figure 1 shows factors considered in making risk
management decisions. 

   Figure 1:  Factors Considered
   in Making Risk Management
   Decisions

   (See figure in printed
   edition.)

Source:  A multinational oil company. 

Generally, the risk-assessment process is a deliberate, analytical
approach to identify which threats can exploit which vulnerabilities
in an organization's specific assets.  These variables are ranked
according to predetermined criteria, such as the probability of a
threat targeting a specific asset or the impact of a vulnerability
being exploited by a specific threat.  The risk-assessment results in
a prioritized list of risks (i.e., threat-asset-vulnerability
combinations) that can be used to select safeguards to reduce
vulnerabilities and create a certain level of protection. 


--------------------
\5 The Commission, a government-private sector body established in
1996, was to develop a national strategy to protect the nation's
critical infrastructures (e.g., banking and finance,
telecommunications, and electric power system) from physical and
computer-based threats. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

We identified several public and private sector organizations that
use threat and risk assessments to manage risk and to identify and
prioritize their security requirements and expenditures to protect
facilities, operations, equipment, and material against terrorist and
other threats.  For example, one company adapted U.S.  government
threat and risk-assessment standards and applied them to more than 19
of its overseas operations.  The company's risk-assessment approach
involves a multidisciplinary team of experts that uses valid threat
information to make judgments about the likelihood and consequences
of an asset (such as a facility) being seized or destroyed, the
asset's criticality, and the asset's vulnerability to various
threats.  The company has applied its risk-assessment process in a
number of areas, from its operations and facilities in Chad to its
hiring practices. 

The NLD program is in the early stages of implementation, and most
cities have not yet received training, assistance, or equipment.  At
the time of our review, threat and risk assessments were not
performed by either the cities or the NLD federal program agencies
for 11 of the first 27 cities selected for assistance.  If properly
applied, threat and risk assessments can provide an analytically
sound basis for building programmatic responses to various identified
threats, including terrorism.  Although threat and risk assessments
are not required in the NLD program, they could help cities
prioritize their investments in WMD preparedness.  Because the
program is in the early stages of implementation, opportunities exist
to make program adjustments that can help target NLD and other
similar programs' training and equipment investments. 

We identified the following challenges to applying an accepted threat
and risk assessment process to cities selected to participate in the
NLD program:  (1) security issues (for example, revealing
intelligence sources and methods) related to providing valid threat
data from the intelligence community to city officials; (2) the lack
of specificity in the intelligence community's threat information;
and (3) the complexity and magnitude of a large city as a subject of
a threat and risk assessment.  These challenges could be overcome
through federal-city collaboration. 


   QUALITATIVE RISK ASSESSMENTS
   ARE BEING USED TO DEFINE
   REQUIREMENTS AND ALLOCATE
   RESOURCES
------------------------------------------------------------ Letter :3

Several federal government and private sector organizations apply
some formal threat and risk-assessment process in their programs. 
For example, the Defense Special Weapons Agency uses a
risk-assessment model to evaluate force protection security
requirements for mass casualty terrorist incidents at DOD military
bases.\6 DOE uses a graded approach to protect its assets based on
risk and vulnerability assessments.  Under the graded approach, DOE
develops and implements security programs at a level commensurate
with the asset's importance or the impact of its loss, destruction,
or misuse.  Also, as required by the Federal Aviation Reauthorization
Act of 1996 (P.L.  104-264), the Federal Aviation Administration
(FAA) and the FBI do joint threat and vulnerability assessments on
each airport determined to be high risk.  Further, three companies
under contract to government agencies (e.g., DOE, the National
Security Agency, the National Aeronautics and Space Administration,
and the Library of Congress) use formal risk-assessment models and
methods to identify and prioritize security requirements.  Moreover,
the President's Commission on Critical Infrastructure Protection
recommended in its final report that threat and risk assessments be
performed on the nation's critical infrastructures.  Appendix I
contains a brief description of selected organizations that use or
recommend threat and risk assessments in their programs. 

One private sector organization we visited--a multinational oil
company--has used threat and risk assessments to determine the
appropriate types and levels of protection for its assets for the
past
3 years.\7 The company's overseas facilities and operations are
exposed to a multitude of threats, including terrorism, political
instability, and religious and tribal conflict.  The company uses
risk assessments to identify and assess threats and risk and to
decide how to manage risk in a cost-effective manner.  For example,
the company has invested in countermeasures for its physical,
operations, personnel, and information security systems and
practices.  The company has applied its risk-assessment process to
more than 19 of its operations, and according to company officials,
the process has resulted in enhanced security and a potential annual
savings of $10 million.  Company officials highlighted the
flexibility of the process in that they have used it to identify
training requirements in a number of areas. 

The company uses a multidisciplinary team of experts to identify and
evaluate threats, assets' criticality, vulnerabilities, and
countermeasures to manage or reduce risk.  The multidisciplinary team
that did the risk assessment of the company's facilities and
operations in Chad, for example, comprised a cultural anthropologist,
a physician, a transportation and logistics specialist, an
intelligence analyst, and some security experts--not to exceed 25
percent of a multidisciplinary team.  Company officials highlighted
the importance of senior management support for threat and risk
assessments and periodic reassessments to ensure that security
countermeasures are appropriate and achieve their intended purpose. 
Over time, countermeasures may become inadequate because of changes
in threat or operations.  The company's objective is to review its
risk assessments every 3 years. 

The company's risk-assessment team generates specific threat
scenarios from valid intelligence and threat data and pairs them with
vulnerabilities in its critical assets.  The multidisciplinary
risk-assessment team then assigns weights or values to these
threat-asset vulnerability pairings according to the likelihood of
such events occurring and the consequences of assets being
compromised or attacked.  This process is based on a DOD military
standard and work by the Department of Transportation's Volpe
National Transportation Systems Center. 

Table 1 shows the DOD standard definitions for the probability that
an undesired event will occur.  The company adapted these definitions
for its assessments. 



                                Table 1
                
                Probability Levels of an Undesired Event

Probability
level             Specific event
----------------  ----------------------------------------------------
A                 Likely to occur frequently
Frequent

B                 Will occur several times
Probable

C                 Likely to occur sometime
Occasional

D                 Unlikely but possible to occur
Remote

E                 So unlikely it can be assumed occurrence may not be
Improbable        experienced
----------------------------------------------------------------------
Source:  Military Standard 882C. 

The company's risk-assessment team quantifies the probability levels'
definitions.  For example, the team might agree that "frequent" means
that an undesired event or threat would occur at least two times per
year or that the odds are 9 in 10 of an incident in annual
operations.  Company officials emphasized that it is not sound
practice to base security programs on worst-case scenarios and
recommended focusing on those scenarios that are more likely to
occur.\8

The company pairs the agreed-upon assessment from table 1 with DOD's
standard for the severity levels of the consequences of an undesired
event (see table 2).  The company has adapted the DOD definitions for
its purposes and included items such as loss of critical proprietary
information and unauthorized access to facilities. 



                                Table 2
                
                   Severity Levels of Undesired Event
                              Consequences

Severity level    Characteristics
----------------  ----------------------------------------------------
I                 Death, system loss, or severe environmental damage
Catastrophic

II                Severe injury, severe occupational illness, major
Critical          system or environmental damage

III               Minor injury, minor occupational illness, or minor
Marginal          system or environmental damage

IV                Less than minor injury, occupational illness, or
Negligible        less than minor system or environmental damage
----------------------------------------------------------------------
Source:  Military Standard 882C. 

This process results in a matrix that pairs and ranks as highest risk
the most important assets with the threat scenarios most likely to
occur. 
Figure 2 is an example of a risk assessment matrix that combines an
analysis of the likelihood and severity of undesired events. 

   Figure 2:  Risk-Assessment
   Matrix

   (See figure in printed
   edition.)

Source:  Adapted from Military Standard 882C and multinational oil
company. 

The assessment team uses the results from the matrix to develop and
recommend security countermeasures for those assets that are most
vulnerable to the most likely threats.  The team reevaluates the cost
benefit and effectiveness of the recommended countermeasures before
submitting them for senior management review.  According to company
officials, their threat and risk-assessment process typically takes 2
weeks to complete and costs about $20,000.  A description of the
company's five-step risk assessment process is in appendix II. 

DOE, the Defense Special Weapons Agency, and three companies under
contract with other government agencies use risk-assessment models or
methods that operate with principles similar to those of the oil
company.  These organizations assemble multidisciplinary teams to do
risk assessments; identify and rank threats, assets, and asset
vulnerabilities; link threat-asset-vulnerability combinations to
produce a rank-ordered list of risks; and identify and prioritize
countermeasures to mitigate current risk levels.  Moreover, four of
the organizations use assessment models that permit real-time
sensitivity analyses, and all of the organizations recommend
periodically reviewing risk-assessment results to verify that
implemented countermeasures are working as expected. 


--------------------
\6 We previously reported on DOD force protection issues in Combating
Terrorism:  Status of DOD Efforts to Protect Its Forces Overseas
(GAO/NSIAD-97-207, July 21, 1997) and Combating Terrorism:  Efforts
to Protect U.S.  Forces in Turkey and the Middle East
(GAO/T-NSIAD-98-44, Oct.  28, 1997). 

\7 Some of the other organizations we identified are in the early
phases of using threat and risk assessments. 

\8 DOE commented that it believes the protection requirements for a
worst-case scenario should at least be reviewed.  It added that
resource restrictions may preclude complete protection against the
worst case but that such cases must be factored into any program. 


   THOUGH NOT REQUIRED, THREAT AND
   RISK ASSESSMENTS COULD HELP
   CITIES PRIORITIZE NLD
   INVESTMENTS
------------------------------------------------------------ Letter :4

The NLD legislation does not require that threat and risk assessments
be performed either to select the cities that will receive assistance
or subsequently to determine selected cities' needs for training and
equipment to deal with WMD terrorism incidents.  According to
information we obtained from DOD; the intelligence community,
including the FBI; and data on 11 of the first 27 cities to receive
NLD training and assistance, the federal government and the cities
have not performed formal, city-specific threat and risk assessments
using valid threat data to define requirements and focus program
investments. 

NLD program agencies provided the first 27 cities information and a
set of questions intended to prompt city officials to examine their
city's ability to respond to a WMD incident.  The information
included a generic list of possible terrorist targets that, if
attacked, could generate mass casualties, including government
facilities; commercial/industrial facilities (including financial
centers, factories, shopping malls, hotels, and water supply and
wastewater plants); transportation centers; recreational facilities;
hospitals; and universities.  The information emphasized that
emergency response personnel must have the equipment necessary to
protect themselves and the victims and instructed cities to determine
whether their equipment was adequate in quality and quantity to
perform the emergency response mission.  The set of questions led the
cities to, among other things, identify additional equipment needs. 

After receiving the information and questions from federal program
agencies, several of the NLD cities generated lists of sites they
considered vulnerable on the basis of very general threat information
or local law enforcement data.  From the data we reviewed on the 11
cities, it is unclear whether individual WMD threats (for example,
individual chemical or biological agents) were categorized in terms
of the likelihood of a successful attack on a given asset, such as a
water supply system or a subway, or the severity of the consequences
of an attack.  Cities also established lists of equipment they
believed would be needed to deal with a WMD terrorist incident
without the benefit of valid threat information from the intelligence
community or a formal risk assessment process using accepted
analytical standards.  For example, one city is using federal funds
to buy chemical protective suits for emergency response personnel,
decontamination trailers, and other items on the basis of general
threat information and identification of heavily trafficked and
populated sites.  This city also is purchasing items and equipment
with its own funds.  NLD cities also are considering the purchase of
chemical and biological detection and identification equipment.  The
NLD legislation does not require cities' lists of potential targets
and equipment needs to be validated by the federal government. 

Since the NLD program is still completing training and assistance in
the first 27 cities, there are opportunities for program adjustments. 
The agencies implementing the NLD program and other appropriate
agencies could work collaboratively with NLD city officials to do
formal threat and risk assessments that use validated threat data and
consider the likelihood of a chemical, biological, nuclear, or
radiological attack.  Officials from the multinational oil company
estimate that a risk assessment on a city could be completed in 2 to
3 weeks.  Therefore, if a similar type of risk assessment was done in
conjunction with city visits or soon thereafter, the city could
receive its training and assistance with little or no delay. 

The FBI is in the best position to take the federal lead in
facilitating city-specific threat and risk assessments.  The FBI,
through the Attorney General, is the lead agency for domestic
terrorism crisis management.  As a member of the intelligence
community, the FBI also collects, analyzes, and reports threat
information on domestic origin threats and targets.  Finally, the
FBI, through its 56 field offices and various joint terrorism task
forces\9 throughout the country, has worked with many of the cities
designated to receive NLD training and assistance. 


--------------------
\9 The joint terrorism task forces are to facilitate an exchange of
intelligence and coordinate activities across the law enforcement
community within a specific geographic area.  The task forces are
staffed by federal, state, and local law enforcement officers. 


   CHALLENGES TO USING THREAT AND
   RISK ASSESSMENTS COULD BE
   OVERCOME
------------------------------------------------------------ Letter :5

To perform realistic threat assessments, federal and city officials
would require access to valid foreign and domestic threat data from
the intelligence agencies and the FBI, respectively; local law
enforcement groups; and public sources.  To the extent possible, this
information should focus on threats faced by individual cities.  The
multinational oil company we visited has personnel cleared to receive
classified threat data that relate to its areas of operation for its
threat and risk assessments, and U.S.  and foreign intelligence
agencies provide the company with such data.  We discussed
intelligence security issues raised by providing threat information
to city officials with the Community Counterterrorism Board\10 and
FBI officials.  These representatives stated that, in principle, the
intelligence community could work with the cities to provide valid
threat data and to validate any threat scenarios generated by
multidisciplinary teams performing city threat and risk assessments. 

The intelligence community's threat estimates and reporting on
foreign-origin terrorism are often general, rarely city specific, and
without further clarification could be difficult to use for threat
and risk assessments of NLD cities.  To overcome this obstacle, the
FAA is working with the FBI to obtain more specific threat
information pertaining to its airport security program.  The FAA
prepared a detailed questionnaire that the FBI is using to help
identify the most likely threats faced by individual major
metropolitan area airports.  From this threat information, a
federal-city risk-assessment team could develop threat scenarios that
the intelligence agencies and the FBI could compare to their foreign
and domestic threat information and analysis and validate with
respect to their realism and likelihood of occurrence. 

Cities are larger and more complex than most entities subject to
threat and risk assessments, such as military bases, ports, and
petroleum processing facilities.  However, size and complexity would
not preclude conducting threat and risk assessments.  For example,
the multinational oil company we visited performed a risk assessment
for its production and export facilities and operations in Chad, a
country with ongoing civil strife.  For that risk assessment, company
officials noted that the multidisciplinary team generated twice as
many threat scenarios (46) as in the average risk assessment.  In
addition, the President's Commission on Critical Infrastructure
Protection recommended that other complex subjects--such as the
nation's telecommunications, transportation, and banking and finance
systems/infrastructures--undergo threat and risk assessments. 


--------------------
\10 The Community Counterterrorism Board is part of the Director of
Central Intelligence's Counterterrorist Center.  Its mission is to
advise and assist the Director of Central Intelligence in
coordinating national intelligence on terrorism-related issues and to
promote the effective use of intelligence resources for this purpose. 
The Board is interagency staffed and functions as the executive
secretariat to the Interagency Intelligence Committee on Terrorism. 


   CONCLUSION
------------------------------------------------------------ Letter :6

Threat and risk assessments are widely recognized as effective
decision support tools for prioritizing security investments, and we
identified several public and private sector organizations that use
them.  While it is not possible to reduce risk to all potential
targets against WMD terrorism, risk assessments can help ensure that
training, equipment, and other safeguards are justified and
implemented based on threat, the vulnerability of the asset to an
attack, and the importance of the asset. 

The NLD program generally allocates $300,000 in training equipment to
each city--much of which also can be used to respond to a WMD
incident.  Currently, cities are receiving training and deciding on
equipment purchases without the benefit of formal threat and risk
assessments.  Threat and risk assessments, if properly done, would be
cost-effective and would help cities get training and select
equipment that would provide the greatest benefit, whether purchased
with NLD program funds, through other federal programs, or with
cities' own funds.  Although there are challenges to doing WMD
terrorism threat and risk assessments of NLD cities, these
difficulties could be overcome through federal and city
collaboration.  While other federal agencies, such as DOD, the
Department of Health and Human Services, and the Environmental
Protection Agency, would be important players on a federal-city risk
assessment team, the FBI is in the best position to lead and
facilitate risk assessments. 


   MATTER FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :7

The Congress may wish to consider amending the Defense Against
Weapons of Mass Destruction Act to require that threat and risk
assessments be included and funded as part of the assistance provided
under the act.  The legislation should specify that the assessments
be a federal-city collaborative effort, with the FBI taking the lead
in facilitating such assessments, with inputs and assistance from the
intelligence community and appropriate federal agencies, including
DOD.  The legislation should allow the FBI to pilot a risk-assessment
approach or model on one or two cities, and make any necessary
adjustments to the model or process before doing risk assessments on
the remaining NLD cities.  The legislation should further provide
that the assessments be used to guide decision-making to determine
cities' training and equipment requirements and their priorities in
alignment with the most likely threat scenarios with the severest
consequences. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :8

The DOE, the FBI, the Federal Emergency Management Agency, the
Central Intelligence Agency, and the DOD reviewed a draft of this
report.  These agencies provided written comments except DOD, which
provided official oral comments.  Written comments and our responses
appear in appendixes III to VI.  DOE agreed that federal-city
collaborative threat and risk assessments should be required in the
NLD program and noted that equipment purchases should be delayed
until risk assessments are complete to ensure that the appropriate
equipment is obtained.  The Federal Emergency Management Agency
strongly endorsed the concept of risk assessment and highlighted the
value of applying such techniques to the threat posed by terrorism. 

We also discussed a draft of this report with officials from the
Department of Transportation, the Department of Health and Human
Services, the Environmental Protection Agency, the President's
Commission on Critical Infrastructure Protection, the National
Research Council, four private sector organizations, and the offices
of emergency management of two NLD cities and with an outside expert. 
These officials generally agreed that threat and risk assessments are
important, beneficial, and applicable to the NLD program.  All of the
agencies, including the Central Intelligence Agency, provided
technical comments that we incorporated as appropriate.  The FBI and
DOD raised concerns about using threat and risk assessments, as
discussed below. 

The FBI raised concerns about the feasibility and cost of doing risk
assessments on subjects the scale of large cities, but was willing to
support a pilot project to assess the application of a threat and
risk-assessment model to cities.  As noted in our report, threat and
risk assessments have been performed on or recommended for other
large, complex subjects such as facilities and operations throughout
the country of Chad and critical national infrastructures like
telecommunications, transportation, and banking and finance systems. 
Our matter for congressional consideration provides for a pilot
effort to test a particular model on one or two cities before
proceeding with risk assessments on the other NLD cities.  For
example, before completing risk assessments on the remaining NLD
cities, a given model may or may not need to be adjusted. 

DOD disagreed with the concept of using threat and risk assessments
to determine cities' requirements for training equipment.  DOD stated
that the threat and risk assessment process is unlikely to make any
difference in the training equipment a city selects.  We believe that
without having properly performed a collaborative federal-city risk
assessment, DOD has little basis for its position.  As noted in our
report, the cities are selecting training equipment without the
benefit of risk assessments, and threat and risk assessments may
change the content of the equipment package selected. 

DOD also emphasized that it loans $300,000 in training equipment and
materials to each city.  We agree that DOD is authorized to loan and
not grant equipment to U.S.  cities under the NLD legislation, but we
note that DOD does not expect or want the cities to return the loaned
equipment.  Whether the equipment is provided by loan or grant has no
bearing on the desirability of performing a threat and risk
assessment with sound inputs and methodology to help managers make
informed judgments relative to aligning resources to needs.  DOD also
expressed concern that the cost of performing assessments would
reduce the amount of equipment cities receive by $20,000 to $30,000. 
We acknowledge the cost of risk assessments.  Nevertheless, we see no
reason why that should preclude a prudent, rational, business-like
assessment of the priority and need for the requested equipment. 

DOD further noted that the FBI is the lead federal agency for
domestic intelligence and has provided no identifiable or specific
WMD terrorist threat to NLD cities.  On the basis of information we
obtained from the intelligence community and organizations that use
risk-assessment processes, judgments about the likelihood of a
variety of chemical and biological agents' successful use in threat
scenarios can be made in the absence of specific threat warning data. 
The Community Counterterrorism Board and FBI also told us they could
assist the federal-city risk-assessment teams in validating scenarios
as to their realism and likelihood.  Finally, DOD stated it is
exploring the possibility of using NLD funds to apply the threat and
risk-assessment process in one city to determine its usefulness for
other domestic preparedness programs.  We are encouraged by DOD's
willingness to consider risk assessments for use in other programs
but continue to believe it also is appropriate for the NLD program. 

In a draft of this report, we recommended that NLD program agencies
require the NLD cities to collaborate with appropriate federal
agencies to perform formal threat and risk assessments with valid
threat data.  We also recommended that the assessments be used to
help define and prioritize NLD cities' requirements for federally
funded equipment purchases for dealing with WMD terrorism.  Based on
comments received and further discussions with agency officials, we
have determined that legislation would be needed to achieve the
intent of our recommendations.  Therefore, we have deleted the
recommendations and included a matter for congressional consideration
that contains the key elements of our original recommendations. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To identify organizations that apply risk management principles to
safeguard assets against numerous threats and assess the
applicability of these principles for the NLD domestic preparedness
program, we interviewed officials and reviewed related documents at
the following organizations: 

  -- Exxon Company International, Florham Park, New Jersey;

  -- Trident Data System, Oakton, Virginia;

  -- Computer Sciences Corporation, Springfield, Virginia;

  -- Science Applications International Corporation, San Diego,
     California;

  -- President's Commission on Critical Infrastructure Protection,
     Rosslyn, Virginia;

  -- Defense Special Weapons Agency, Force Protection Office,
     Alexandria, Virginia;

  -- DOE, Office of Safeguards and Security, Germantown, Maryland;

  -- FBI, National Security Division, Domestic
     Terrorism/Counterterrorism Planning Section, Washington, D.C.;

  -- Office of the Director of Central Intelligence, Community
     Counterterrorism Board, Washington, D.C.;

  -- FAA, Office of Civil Aviation Security Operations, Washington,
     D.C.;

  -- Department of Transportation, Research and Special Programs
     Administration, Washington, D.C.; and

  -- National Academy of Sciences, National Research Council,
     National Materials Advisory Board, Washington, D.C. 

We also met with officials from DOD, DOE, the FBI, and the Community
Counterterrorism Board to discuss the WMD terrorism threat and
reviewed pertinent documentation, including a relevant National
Intelligence Estimate and update. 

To determine how cities that were selected for the NLD domestic
preparedness program established their emergency response
requirements for dealing with WMD terrorist incidents, we reviewed
documents and met with DOD officials from the Office of the Assistant
Secretary of Defense for Special Operations and Low-Intensity
Conflict; the Office of the Army Deputy Chief of Staff for Operations
and Plans, Military Support Division; and the Army Chemical and
Biological Defense Command, Domestic Preparedness Office.  We also
reviewed documents and met with officials from the FBI's Domestic
Terrorism/Counterterrorism Planning Section; DOE's Office of
Emergency Management; and the Federal Emergency Management Agency's
Terrorism Coordination Unit.  Additionally, we spoke with city
emergency management officials from New York City, New York, and
Philadelphia, Pennsylvania.  We also reviewed documents available at
the time of our review for 11 of the first 27 cities scheduled for
NLD program assistance. 

We conducted our review from September 1997 to January 1998 in
accordance with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :9.1

As agreed with your offices, unless you publicly announce the
contents of this report earlier, we plan no further distribution of
this report until
5 days after its issue date.  At that time, we will send copies to
the appropriate congressional committees; the Director, Office of
Management and Budget; the federal agencies discussed in this report;
and other interested parties.  If you have any questions about this
report, please contact me at (202) 512-3504.  Major contributors to
this report were
Davi M.  D'Agostino and Marc J.  Schwartz. 

Richard Davis
Director, National Security
 Analysis


SELECTED ORGANIZATIONS THAT USE OR
RECOMMEND THREAT AND RISK
ASSESSMENTS IN THEIR PROGRAMS
=========================================================== Appendix I


   FEDERAL AVIATION
   ADMINISTRATION--FEDERAL BUREAU
   OF INVESTIGATION JOINT THREAT
   AND VULNERABILITY ASSESSMENTS
--------------------------------------------------------- Appendix I:1

Section 310 of the Federal Aviation Reauthorization Act of 1996
(P.L.  104-264) requires the Federal Aviation Administration (FAA)
and the Federal Bureau of Investigation (FBI) to conduct joint threat
and vulnerability assessments every 3 years, or more frequently as
necessary, at each airport determined to be "high risk." The FAA has
identified a number of airports likely to be high risk based on the
operational characteristics of an airport, such as flight activity
and the number of carriers.  These airports account for about 92
percent of all passenger airplane boardings in the United States. 

The FBI is providing threat data (i.e., intelligence and law
enforcement information) that the FAA is using to develop threat
assessments specific to the airport or the metropolitan area in which
the high-risk airport is located.  The FAA has developed a
questionnaire to assess, quantify, and rank airport vulnerabilities. 
The questionnaire, which contains almost 400 items, was field tested
in December 1997 at Baltimore-Washington International Airport. 
Washington-Dulles International Airport was assessed in January 1998,
and beginning in February 1998, two airports per month will be
assessed.  A team of FBI, FAA, and airport officials are completing
the questionnaire; however, the FAA is interpreting the results and
recommending countermeasures. 


   DEFENSE SPECIAL WEAPONS AGENCY
   VULNERABILITY ASSESSMENTS
--------------------------------------------------------- Appendix I:2

In response to the Khobar Towers bombing in Saudi Arabia in 1996, the
Chairman of the Joint Chiefs of Staff tasked the Defense Special
Weapons Agency with performing vulnerability assessments.  Assessment
teams plan to visit more than 500 of the highest priority Department
of Defense (DOD) facilities located within the United States and
abroad, with the goal of conducting 100 assessments per year.\1

After the first 6 months, 47 assessments had been completed.  These
vulnerability assessments focus mainly on mass casualty incidents
caused by high-intensity explosives, considered to be the most likely
threat, but incidents involving weapons of mass destruction are also
being considered. 

A vulnerability assessment team consists of experienced military and
civilian personnel from a range of disciplines, including structural
and civil engineering, security, and operations readiness.  The
assessment team uses a risk-assessment model to identify and rank
order a site's strengths and weaknesses.  The specific elements of
the model include asset criticality, site vulnerability, and the ease
with which a threat can gain access to an asset. 


--------------------
\1 The Defense Special Weapons Agency defines a DOD facility as a
fixed installation with at least
300 persons. 


   DEPARTMENT OF ENERGY'S ONGOING
   NUCLEAR SECURITY PROGRAM
--------------------------------------------------------- Appendix I:3

The Department of Energy (DOE) states it uses a Design Basis Threat
to develop security policy and requirements, to help plan its
security program, and to help with facility design.  The Design Basis
Threat is based on a fusion of threat and intelligence assessments
provided by numerous sources that address potential threat activities
and adversaries.  DOE develops and models threat scenarios that link
specific threats to specific asset vulnerabilities.  DOE uses these
scenarios to select countermeasures designed to reduce the current
level of risk.  This analysis is based on a graded protection
concept,\2 under which varying levels of protection are acceptable
based on the value of the assets being protected. 

Each DOE facility is required to conduct a vulnerability assessment
to identify possible paths a threat may take to reach an asset. 
Threats are prioritized according to their potential impact and
assigned consequence values that reflect their relative ranking.  For
example, a compromised assembled nuclear weapon has a significantly
higher consequence value than does a stolen or diverted Category III
material.  DOE notes that the vulnerability assessment process
provides a method for allocating security resources according to the
level of risk.  DOE has several automated tools it uses to conduct
its vulnerability assessments. 


--------------------
\2 DOE designates each of its facilities as Category I, II, III, or
IV.  A facility designated as a Category I is the highest priority,
followed by II, III, and IV in descending order of priority. 


   SURFACE TRANSPORTATION
   VULNERABILITY ASSESSMENT
--------------------------------------------------------- Appendix I:4

In accordance with the Omnibus Consolidated Appropriations Act for
Fiscal Year 1997, the Department of Transportation's Research and
Special Programs Administration is conducting a comprehensive
vulnerability assessment of the U.S.  surface transportation
infrastructure (i.e., road, rail, transit, pipeline, and maritime). 
The goal of the assessment is to (1) identify and rank key threats to
and critical vulnerabilities of the national transportation
infrastructure and (2) recommend possible countermeasures to improve
infrastructure protection from a host of threats such as terrorism,
accidents, and natural disasters.  This assessment is scheduled to be
completed in June 1998. 

Based on the results of the vulnerability assessment, a National
Research Council Advisory Study will attempt to identify technologies
and processes to improve surface transportation security against
threats that could seriously disrupt safety and operations.  A final
report is expected in the spring of 1999. 


   THE PRESIDENT'S COMMISSION ON
   CRITICAL INFRASTRUCTURE
   PROTECTION
--------------------------------------------------------- Appendix I:5

President Clinton signed Executive Order 13010 on July 15, 1996,
establishing the President's Commission on Critical Infrastructure
Protection.  The Commission's mandate was to develop a national
strategy for protecting the country's critical infrastructures from a
spectrum of threats and assuring their continued operation.  The
eight critical infrastructures include the electric power system; gas
and oil (storage and transportation); telecommunications; banking and
finance; transportation; water supply systems; emergency services
(including medical, police, fire, and rescue); and continuity of
government operations.  Threats to these infrastructures fall into
two categories:  physical threats to tangible property and
computer-based attacks on the information or communications
components that control critical infrastructures.  Because many of
the critical infrastructures are privately owned and operated, the
Commission comprises representatives from the federal government and
the private sector. 

The Commission issued its final report to the President on October
20, 1997.  The report concluded that the owners and operators of
critical infrastructures lack sufficient threat and vulnerability
information to make informed risk management decisions. 
Consequently, the Commission recommended that owners and operators,
in collaboration with the federal government, conduct periodic
threat, vulnerability, and risk assessments. 


A MULTINATIONAL OIL COMPANY'S
FIVE-STEP QUALITATIVE
RISK-ASSESSMENT PROCESS
========================================================== Appendix II


   STEP 1:  DETERMINE THE VALUE OF
   ASSETS AND JUDGE CONSEQUENCES
   OF LOSS
-------------------------------------------------------- Appendix II:1

Critical assets that require protection are identified and ranked
according to what their loss would represent.  At the outset, the
company forms a risk-assessment team of five to eight individuals
from various disciplines, including security, emergency or asset
management, finance, senior management, information systems, and
cultural anthropology.  Team members are generally dedicated full
time to the risk assessment.  The team agrees on the period of time
to be covered by the risk assessment (for example, to the year 2010);
the physical boundaries of the assessed activity; and the
consequences of concern (for example, safety, public disruption,
environmental effects, financial impact).  The company uses the
descriptive values in DOD's Military Standard 882C, System Safety
Program Requirements, to categorize the loss as either catastrophic,
critical, marginal, or negligible.  The risk assessment team also
assigns values to key assets. 


   STEP 2:  IDENTIFY THREATS AND
   PAIR WITH ASSETS
-------------------------------------------------------- Appendix II:2

Threat identification is the most important step in the
risk-assessment process.  If threats are not accurately identified,
the risks they represent cannot be reduced or eliminated.  Threats
the company is concerned with include trusted or incompetent
insiders, criminals, terrorists, and environmental and system-induced
threats.  In characterizing the threat, the company examines the
historical record of security and safety breaches and obtains
location-specific threat information from the intelligence community
and open sources.  These threats are then paired with company assets
that represent likely targets. 


   STEP 3:  IDENTIFY ASSET
   VULNERABILITIES
-------------------------------------------------------- Appendix II:3

The risk-assessment team identifies weaknesses in the company's
critical assets that could be exploited by the threats identified in
step 2 and determines their nature and source.  Methods used to
identify vulnerabilities include evaluating data obtained through
surveys and historical data from related incidents and applying
formal vulnerability analysis techniques.  Asset vulnerabilities can
include operations and processes, policies and procedures, physical
and technical security, information security, personnel security, and
operations security. 


   STEP 4:  DETERMINE RISK THROUGH
   SCENARIOS
-------------------------------------------------------- Appendix II:4

The risk-assessment team develops credible risk scenarios to describe
how undesired events may occur and to determine the effect of each
undesired event on the company's assets.  The set of scenarios may
not be an exhaustive list of all possible undesired events, but each
valid threat that has been identified should be represented in at
least one scenario.  The oil company typically develops 20 to 25
scenarios for each of its risk assessments.  The team assigns a
high-, medium-, moderate-, or low-risk rating for each scenario based
on the severity of consequences and the likelihood of each scenario
occurring.  Before likelihood values are assigned, the team must
agree on the time period under study and a quantitative definition of
the descriptive rankings.  For example, the team might agree that
"frequent" means that an undesired event or threat would occur at
least two times per year, or that the odds are 9 in 10 of an incident
occurring in annual operations for the duration of the study period. 
Company officials stated that they avoid focusing on worst-case
scenarios that are not likely to occur. 


   STEP 5:  IDENTIFY ACTIONS, AS
   NECESSARY, THAT LEAD TO RISK
   REDUCTION
-------------------------------------------------------- Appendix II:5

Countermeasures are actions that either eliminate the causes or
reduce the effects of one or more vulnerabilities.  Countermeasures
could include additional checkpoints controlling access to a
facility, security cameras, personnel background investigations, new
procedures, or chemical protective gear.  Countermeasures are
identified and inserted into a scenario, and the risk rating for that
scenario is recalculated to account for the effect of the
countermeasure.  The company selects countermeasures on the basis of
factors such as whether they reduce the probability of an undesired
event occurring, their implementing cost, and any additional
enforcement and audit requirements.  Countermeasures can be
prioritized by considering a number of factors, including the amount
of resulting risk reduction, cost, difficulty to implement, or a
combination thereof.  Usually, there is a point beyond which adding
countermeasures will raise costs without appreciably enhancing the
protection afforded. 




(See figure in printed edition.)Appendix III
COMMENTS FROM THE DEPARTMENT OF
ENERGY
========================================================== Appendix II



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on DOE's letter, dated March 9,
1998. 

GAO COMMENTS

1.  We modified the text to reflect DOE's comment. 

2.  We agree that it is prudent to delay the purchase of equipment
until a vulnerability or risk assessment is complete to ensure that
the appropriate equipment is obtained. 

3.  We were briefed on the Value Added Model in our meetings with
officials from DOE and the multinational oil company, and the
business school that DOE refers to.  Oil company officials stated
that they were using this model in their risk assessments to assess
and compare the financial impact of various security strategies.  We
note, however, that other measures of effectiveness exist. 
Therefore, we omitted a discussion of the Value Added Model from this
report to avoid emphasizing one criterion--the financial cost benefit
of competing sets of countermeasures--over others that can also lead
to risk reduction. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE FEDERAL BUREAU
OF INVESTIGATION
========================================================== Appendix II



(See figure in printed edition.)


The following are GAO's comments on the FBI's letter, dated March 4,
1998. 

GAO COMMENTS

1.  We agree, and our report notes, that the Nunn-Lugar-Domenici
(NLD) legislation did not require that threat and risk assessments be
performed either to select the cities that will receive assistance or
to determine those cities' needs for training and equipment to deal
with weapons of mass destruction (WMD) terrorism incidents.  However,
the legislative history of the Defense Against Weapons of Mass
Destruction Act of 1996 contains no substantive discussion or any
other indication of what criteria should be used to select the cities
or determine their training and equipment needs.  We agree that
earlier studies have identified training and equipment that would
enhance the capabilities of city emergency personnel to respond to
WMD terrorism.  However, as noted in our report, without a formal
threat and risk-assessment process to define requirements, it is
unclear that the training and equipment selected will provide the
greatest benefit to the cities. 

2.  Our matter for congressional consideration provides for a pilot
effort to test a particular model on one or two cities before
proceeding with risk assessments on the other NLD cities.  For
example, before completing risk assessments on the remaining NLD
cities, a given model may or may not need to be adjusted. 




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



(See figure in printed edition.)


The following are GAO's comments on the Federal Emergency Management
Agency's letter, dated February 27, 1998. 

GAO COMMENTS

1.  On the basis of agency comments we received and further
discussions with agency officials, we added a matter for
congressional consideration and eliminated our draft recommendation. 
The matter for congressional consideration would clarify NLD
legislation to require threat and risk assessments in the program. 
Regarding the issue of sharing threat information, officials from the
intelligence community, including the FBI, stated that they could
work with the NLD-selected cities to provide valid threat data and to
validate any threat scenarios generated by multidisciplinary teams
performing threat and risk assessments.  In addition, the Central
Intelligence Agency and the FBI did not raise such concerns in their
official comments on a draft of this report. 




(See figure in printed edition.)Appendix VI
COMMENTS FROM THE CENTRAL
INTELLIGENCE AGENCY
========================================================== Appendix II



(See figure in printed edition.)


The following are GAO's comments on the Central Intelligence Agency's
letter, dated March 6, 1998. 

GAO COMMENTS

1.  We modified the text to reflect the Central Intelligence Agency's
comment. 



RELATED GAO PRODUCTS
=========================================================== Appendix 0

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


*** End of document. ***