National Guard Civil Support Teams: A 24/7 Response to Weapons of Mass Destruction

University of St. Thomas Law Journal, Mar 2018

Larry A. Shireley

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National Guard Civil Support Teams: A 24/7 Response to Weapons of Mass Destruction

omas Law Journal National Guard Civil Support Teams: A 24/7 Response to Weapons of Mass Destruction Larry A. Shireley - Article 9 ARTICLE NATIONAL A 24/7 GUARD RESPONSE MASS CIVIL SUPPORT TO WEAPONS DESTRUCTION TEAMS: OF LT. COL. LARRY A. SHIRELEY* I. INTRODUCTION In the 1990s, the changing political and military climate, accompanied by a series of events including the World Trade Center bombing in 1993, the Oklahoma City bombing and the release of sarin in the Tokyo subway, both in 1995, prompted significant concerns regarding domestic terrorism. In response, President Clinton, Congress, and the Department of Defense (DOD), initiated a review of the plans and strategies for homeland defense. Assessments of readiness and response capabilities indicated there were serious shortfalls in our defenses against both international and domestic terrorism.1 In response, President Clinton issued Presidential Decision Directive (PDD) 39 in June 1995, which outlined steps to ensure that the United States was prepared to combat domestic and international terrorism.2 Furthermore, he directed that the Federal Response Plan be reviewed to ensure its adequacy to respond to the consequences of terrorism directed against large populations in the United States, including terrorism involving weapons of mass destruction (WMDs).3 As a consequence, the Defense Against Weapons of Mass Destruction Act of 1996 was enacted, which * Commander, 81st CST, North Dakota National Guard. The author would like to acknowledge Murray Sagsveen for his confidence, support, and friendship during the past several years. 1. PRESIDENTIAL DECISION DIRECTIVE 39 U.S. POLICY ON COUNTERTERRORISM (June 21, 1995), available at (describing efforts to reduce vulnerabilities). 2. Id. 3. Id. (“The Director of the Federal Emergency Management Agency [FEMA] shall ensure that the Federal Response Plan [FRP] is adequate to respond to the consequences of terrorism directed against large populations in the United States, including terrorism involving [WMDs].”). mandated enhancing domestic preparedness and response capability for terrorist acts involving WMDs.4 Reviews of our defense against domestic terrorism indicated that the National Guard could—and should—play a major role in the emergency responses to a use or threatened use of WMDs or similar incidents in the United States. Throughout its long history, the National Guard has demonstrated its utility and capacity to respond to domestic events and disasters. Lieutenant General Steven Blum, former National Guard Bureau Chief and current Deputy Combatant Commander at United States Northern Command, illustrated this when he said, “The successful integration of civilian and military cultures and capabilities has long been one of the strengths of the National Guard.”5 Deborah R. Lee, Assistant Secretary of Defense for Reserve Affairs, outlined why the National Guard should play a major role in the response to a domestic WMD event at the Association of Military Surgeons of the United States annual meeting on November 17, 1997. Ms. Lee noted that “[t]hey are readily familiar with the local area. They know its plans, they know its infrastructure, and they certainly know the geography. They also have strong community links that will be invaluable in times of crisis.”6 As it became clear that the National Guard would play a major role in the national response plan against WMDs, various strategies were discussed and formulated. In 1998, the DOD commissioned a “Tiger Team” to develop a strategic plan for responding to attacks using WMDs.7 The Tiger Team review indicated there were significant gaps in the civilian community for an adequate response to WMD events.8 The Tiger Team developed the concept of specialized National Guard teams to assist first responders during such events. Consequently, the Rapid Assessment and Initial Destruction (RAID) team concept was included in the Tiger Team report to the Secretary of Defense in January 1998, with the recommendation that at A 24/7 RESPONSE TO WEAPONS OF MASS DESTRUCTION 649 least a partial RAID team be established in each state and territory.9 President Clinton made the first formal reference to the formation of RAID teams during his address at the Naval Academy commencement on May 22, 1998,10 and beginning in fiscal year (FY) 1999, Congress authorized funding to train, organize, and equip RAID teams.11 The legislation forming the RAID teams describes a RAID team member as a member of the National Guard serving on full-time National Guard duty under section 502(f) of title 32 in connection with functions referred to in subsection (a), may, subject to paragraph (3), perform duties in support of emergency preparedness programs to prepare for or to respond to any emergency involving any of the following: (A) The use or threatened use of a weapon of mass destruction (as defined in section 12304(i)(2) of this title) in the United States. (B) A terrorist attack or threatened terrorist attack in the United States that results, or could result, in catastrophic loss of life or property. (C) The intentional or unintentional release of nuclear, biological, radiological, or toxic or poisonous chemical materials in the United States that results, or could result, in catastrophic loss of life or property. (D) A natural or manmade disaster in the United States that results in, or could result in, catastrophic loss of life or property.12 The RAID concept had a unique federal-state relationship. The teams were to be federally funded, principally federally-trained, but under the command and control of the governors of the states in which they were located and under the operational command and control of the adjutant generals of those states. This would allow them to immediately respond to an incident as part of a state response, before federal assets could be requested and approved. The ten initial full-time RAID teams were strategically established in each of the Federal Emergency Management Agency (FEMA) regions in Massachusetts, New York, Pennsylvania, Georgia, Illinois, Texas, Missouri, Colorado, California, and Washington. The initial implementation plan was that the remaining forty-four states and territories would have RAID teams composed of “traditional” National Guard members rather than having full-time teams. In subsequent years however, additional fulltime teams were approved and funded by Congress, which ultimately led to every state and territory having a full-time RAID team with passage of the FY 2003 National Defense Authorization Act.13 In 1999, the name “RAID” was changed to “Civil Support Team” (CST) to more accurately reflect its primary mission as a supporting element to first responders. THE CST MISSION CSTs are unique among military units in that their primary mission, as the name implies, is to provide support for civilian first responders. In order for CSTs to provide this support, CST members are required to complete significant and rigorous initial and refresher coursework, be equipped with state-of-the-art equipment and become experts with its use, and participate in frequent training exercises to enable them to efficiently operate in a hazardous environment. CSTs have been referred to as the military’s first responders, but except in rare situations, CSTs are not the first on the scene, but rather are deployed upon a request for assistance by the civilian incident commander (IC). There is often a perception that when military units are called into action, they take command of the situation. Although the command element of the CST maintains control of the team, the civilian IC maintains control and authority over the incident. There are situations, however, when the CST may be pre-deployed, such as during a national security special event. Examples of events at which CSTs have been pre-staged for monitoring and rapid response include the Republican and Democratic national conventions, presidential inaugurations, and major sporting events, such as the World Series and Super Bowl. III. CST COMPOSITION AND CHARACTERISTICS Each CST is composed of twenty-two full-time National Guard members with seven officers and fifteen enlisted members. They are Title 32 National Guard members, meaning they are under the control of the adjutant general and the governor rather than the active duty or federal Title 10 13. Press Release, U.S. Dep’t of Def., Weapons of Mass Destruction-Civil Support Team Certified for Guam and the United States Virgin Islands (June 2, 2009), available at http:// (“The teams certified today bring the total number of teams certified by DOD to 55, which completes the 55 authorized by Congress to ensures [sic] one team is fielded in every state, territory, and the District of Columbia.”). A 24/7 RESPONSE TO WEAPONS OF MASS DESTRUCTION 651 military force. CSTs are usually composed of both Army and Air National Guard members. The national allocation is 80 percent Army and 20 percent Air personnel; however the actual distribution of Army-to-Air on individual teams varies. CSTs may be “federalized” and deployed as part of a federal response to an incident in or outside the CST assigned state. To date, however, no CST has been federalized. CSTs are currently restricted to training and responding within the United States or its territories, although that restriction is under review. They are centrally funded by the National Guard Bureau, but CSTs often receive supplemental funding from their state for equipment and training. Upon formation, each team is provided standardized equipment to enable it to respond to a WMD event, but because of the unique characteristics of each state, individual CSTs augment their core equipment to enable them to better respond in their respective states. Obviously there are different response needs and requirements in Alaska than in Florida. Some of the equipment is military in nature, or “green gear,” but most is purchased commercially, or “over-the-counter,” in order to increase interoperability with civilian first responders. TRAINING AND CERTIFICATION Each CST must be initially certified by the DOD. It takes approximately fifteen to eighteen months after initial team formation to complete the specified core curriculum and the training required for certification. Each CST member must complete the eight-week Civil Support Skills Course (CSSC) conducted by the Army at Fort Leonard Wood, Missouri. In addition to the CST-specific training at CSSC, each CST team member must also successfully complete the requirements for Hazardous Materials (HAZMAT) technician certification. During the first fifteen months, each team member is required to complete an average of 650 course hours; certain CST members, however, must complete more than one thousand course hours for their position. It is rare for CST members to be together as a team during the first twelve to fifteen months because of the considerable coursework. During this initial period, teams also conduct training to become familiar with equipment, and to develop and practice techniques, tactics, and procedures. The teams also train and conduct exercises with local first responders. Once the initial coursework and training is completed, a team from Army North (ARNORTH) experienced in WMD and HAZMAT response conducts an external evaluation (EXEVAL) to ensure the CST is mission-ready. This EXEVAL involves a series of practical exercises including realistic scenarios that are designed to test each section of the team. Upon successful completion of the initial EXEVAL, a formal certification request is submitted to the DOD. As of June 2, 2009, all CSTs have been certified.14 CST ACTIVATION Once the CST is certified, it can respond to requests for assistance. The CST’s primary responsibilities are to rapidly deploy to: (1) assess a suspected chemical, biological, radiological, nuclear, or explosive (CBRNE) event in support of a local incident commander; (2) identify CBRNE agents/substances; (3) advise civilian responders regarding appropriate response actions; and ( 4 ) assist/facilitate requests for assistance of additional state and federal assets.15 Procedures vary slightly from state to state, but CST request and activation procedures are similar. Each event begins locally, with the initial response conducted by local first responders. The local IC, who is responsible for command and control of the incident, conducts an initial assessment and supervises the incident response. If the IC’s assessment indicates that additional resources are necessary, the IC will request assistance through a local emergency manager or a person of equivalent function. The request is then reviewed and evaluated by a state coordinating official.16 Requests for CST assistance must meet certain validation criteria such as: Is the request feasible? Does it meet the legal requirements for a CST response? Is the request supportable by the CST (i.e., is the request within the CST capabilities)? Is it worth the risk? Is it an appropriate request?17 Once these criteria are met, the state coordinating officer will notify the CST commander of the validated request for assistance, and provide the most current information regarding the situation. The adjutant general and the governor’s office also will be contacted regarding the request for CST assistance. This process normally takes only a few minutes. Once the mission request is validated, the CST commander will contact the IC and begin coordinating the CST’s response, including notification of CST members. CSTs are available twenty-four hours a day, seven days a week, and most CSTs have some sort of mandatory on-call status.18 14. Id. 15. DEP’T OF THE ARMY AND THE AIR FORCE, WEAPONS OF MASS DESTRUCTION CIVIL SUPPORT TEAM MANAGEMENT 2 (2006), available at angi10_2503.pdf. [hereinafter WEAPONS] (“The mission of the WMD CST is to support civil authorities at a domestic CBRNE incident site by identifying CBRNE agents/substances, assessing current and projected consequences, advising on response measures, and assisting with requests for additional support.”). 16. Id. at 5–7. 17. Id. at 5 (“The AG, or designated authority, must review the mission to ensure that the assistance is: properly requested from or verified with an official source; feasible; legal; supportable; worth the risk; and appropriate for the current force protection condition.”). 18. Id. at 3 (“These CSTs can be available 24 hours a day, 7 days a week for rapid deployment for response operations. . . . [A] designated number of CSTs are always ready to respond to a national need, or the need of a state without an available CST.”). A 24/7 RESPONSE TO WEAPONS OF MASS DESTRUCTION 653 THE ANATOMY OF A CST: SETUP AND CAPABILITIES CSTs are fully self-contained and self-supporting and are comprised of six different sections: command, operations, administration/logistics, communications, medical, and survey. The command section is responsible for conducting primary liaison with the IC and overall coordination of CST activities. Upon arrival at an incident site, the CST commander receives the IC’s objectives and obtains updated situational information. The commander advises the IC of the CST assets, capabilities, and limitations, and coordinates with the IC throughout the event while providing team oversight to meet the IC’s objectives. The administration/logistics section is responsible for ensuring that the CST has adequate supplies and equipment for a response. Members of this section document expenditures and used/depleted equipment and supplies that require replacement; they are also often responsible for CST decontamination activities. CSTs are only able to conduct decontamination of CST members because of the relatively limited number of personnel; CSTs are unable to conduct mass decontamination. If a decontamination system has already been established by civilian first responders, CST members may request to utilize and augment that system rather than establish their own decontamination line. Once on-site, the CST establishes its own operations center to monitor internal communications and conduct response planning. Operations center personnel monitor communications between down-range team members and ensure that the commander is provided current information regarding significant activities and findings. This enables the commander to keep the IC current on CST activities and to coordinate team actions to ensure that the IC’s objectives are being met. A hazard modeling specialist in the operations section utilizes specialized computer programs such as the Hazardous Predictions and Assessment Capabilities (HPAC) software, Consequence Assessment Tool Set (CATS), or the web-based program of the National Atmospheric Release Advisory Center (NARAC) to provide information regarding the potential impact of the release of the hazardous substances. Utilizing these tools, the hazard modeler is able to provide estimates of current and future impacts on the affected population, areas of greatest risk, and potential health effects. This information assists the IC in assessing whether to evacuate people or have them remain sheltering-in-place, and in implementing a plan to care for the exposed population. Communications During any crisis or disaster situation, one of the most critical needs is accurate and consistent communications. When communication problems occur, such as inoperability between responders, the mission’s success is at risk. CST resources are available to help ensure that communication systems are available and interoperable. Two of the CST’s vehicles—the Advanced Echelon Vehicle (ADVON) and the Unified Command Suite (UCS)—are designed and equipped to provide robust communication assets. The ADVON vehicle is initially deployed to the incident site to establish liaison with the IC and is equipped with fax and printer capabilities, satellite telephones, a secure telephone terminal, Internet access, and the IC’s Radio Interface (ICRI), which provides tactical radio interfaces for interoperability between emergency response personnel. The UCS provides communications operability within the CST, enables interoperability between responders, and provides the ability to obtain worldwide technical and logistical assistance for the CST and the IC. Communication assets provided by the UCS include secure Internet access, the Tactical Digital Intercommunications System (TDIS)—which allows access to multiple radios—KU satellite band, UHF and VHF radios, a wide-area network station, and video and radio conferencing capabilities. One of the most valuable assets provided by the UCS is the ACU-1000, which provides interconnections between different communications systems. The ACU-1000 can simultaneously cross-band two or more different radio networks, connect a radio network to a telephone line, and create a conference call between several different radio networks and telephone lines. The CST medical section’s primary responsibility is to provide medical care for team members. However, the highly trained team is also a valuable resource for community medical care providers. During a CST response, the medical section coordinates with community providers and advises them on testing and treatment protocols. In addition, the medical section is able to conduct and provide worldwide medical consultation with both military and civilian experts. The CST also has a completely self-contained mobile medical laboratory known as the Analytical Laboratory System (ALS), which provides onsite analysis of chemical, biological, and radiological agents. Samples collected by CST members are brought into the ALS for analysis that is conducted in a certified Biosafety Level 3 (BSL 3) containment glove box.19 19. CTRS. FOR DISEASE CONTROL AND PREVENTION AND NAT’L INSTS. OF HEALTH, U.S. DEP’T OF HEALTH AND HUMAN SERVS., BIOSAFETY IN MICROBIOLOGICAL AND BIOMEDICAL LABORATORIES 17 (5th ed. 2007), available at (“Biosafety level 3 (BSL-3) is appropriate for agents with a known potential for aerosol transmis A 24/7 RESPONSE TO WEAPONS OF MASS DESTRUCTION 655 The ALS is equipped with a gas chromatograph/mass spectrometer (GC/ MS) for chemical analysis, which is able to identify nearly two hundred thousand different chemicals. The ALS also has Fourier Transform Infrared (FTIR) spectroscopy to identify various organic and inorganic materials; it is especially valuable in identifying materials in mixtures. A fluorescent microscope is available to identify solid particulate chemicals and biological agents and is utilized when examining suspicious powders. The ALS utilizes immunoassay tests to initially screen for biological agents, and polymerase chain reaction (PCR) testing, which uses DNA for specific identification. Although the ALS has robust capabilities for chemical and biological analysis, it is not a confirmatory laboratory. Therefore, CSTs coordinate closely with state laboratories and conduct periodic exercises with them. Samples received by the ALS are prepared, split, and sent for confirmatory analysis to state or other laboratories such as the Federal Bureau of Investigation (FBI), as the IC directs. In addition, the USC utilizes a digital transmission link, which enables laboratory results, photographs, and other pertinent information to be sent to other scientific experts for review and consultation. The individuals operating the laboratory receive extensive training in sample preparation and analysis; their proficiency is tested monthly on unknown samples. Currently, pilot testing is being conducted with select CSTs for International Organization for Standardization (ISO) 17025 certification, which is the main standard used by testing and calibration laboratories.20 This certification will allow for better integration between CSTs and civilian laboratories within the national Laboratory Response Network. The core of the CST is the survey section. Although all CST members are HAZMAT-technician certified, it is normally the survey section members that enter the contaminated area, commonly referred to as the “hot zone” to conduct site characterization, down-range monitoring, and on-site agent identification and sample collection. Utilizing specialized equipment, survey team members are able to provide preliminary identification of biological, chemical, and radiological agents. In addition to conducting downrange monitoring, the team may also collect samples for testing in the ALS. The team does not collect the samples as “evidence,” although CST members utilize procedures that, if necessary, would withstand the scrutiny of a legal examination. These procedures include proper sample collection, hansion, for agents that may cause serious and potentially lethal infections and that are indigenous or exotic in origin.”). 20. See INT’L ORG. FOR STANDARDIZATION/INT’L ELECTROTECHNICAL COMM’N, GENERAL REQUIREMENTS FOR THE COMPETENCE OF TESTING AND CALIBRATION LABORATORIES, at iv (1st ed. 1999) (“ISO . . . and IEC . . . form the specialized system for worldwide standardization.”). 15-JAN-10 9:44 656 UNIVERSITY OF ST. THOMAS LAW JOURNAL dling, and chain of custody techniques. This down-range monitoring and initial detection provides important information for the IC in the decisionmaking process, and is also invaluable for the early treatment of exposed persons. CST members entering the hot zone utilize personal protective equipment required by the Occupational Safety and Health Administration (OSHA).21 Protection levels range from A-D, with the type of protection utilized determined situationally, based on the level of protection required. Level A protective equipment provides the greatest protection and is used when skin, respiratory, and eye protection is required. Level A personal protective equipment involves wearing a fully-encapsulated suit with a selfcontained breathing apparatus. In addition to 60–minute breathing apparatuses, which are typically used by civilian responders, CSTs are also equipped with rebreathers. A rebreather is a closed-circuit breathing apparatus that allows users to operate in the hot zone up to four hours. The additional time in the hot zone provided by the rebreathers allows the team to conduct site characterization and down-range monitoring more efficiently. The team entering the hot zone may be composed of only CST members, or may also include civilian responders. Therefore, frequent training is conducted between the CSTs and their civilian counterparts to become better accustomed to one another’s operating practices. CST DEPLOYMENT Because CSTs are primarily state assets, their main areas of operation are their respective states. When CSTs respond, it is usually by driving to the site with eight specially-designed and equipped vehicles. Depending on the situation and distance, however, CSTs may also employ air assets such as military helicopters for rapid deployment. It is impossible to deploy the entire team via helicopter, but an advance team may be sent in this fashion in order to provide more timely assistance for the IC until additional CST assets arrive. CSTs commonly conduct periodic training with their state aviation units to help ensure that they are able to effectively utilize air assets for response and deployment. Nationally, CSTs are divided into six response sectors, which correspond to geography rather than state lines or FEMA regions. The National Guard Bureau has developed a Response Management Plan designating one CST as the primary back-up team each month for each sector; this on-call status is referred to as a team’s “GOLD” cycle.22 If an event requiring additional CST assistance occurs in that sector, the team in “GOLD” status would likely be requested to respond. In many instances, however, the distance between the state of initial response and the back-up CST is too far 21. 29 C.F.R. § 1910.120 App. B (2008). 22. WEAPONS, supra note 15, at 4 (“The designation for Immediate Response is GOLD.”). A 24/7 RESPONSE TO WEAPONS OF MASS DESTRUCTION 657 for an expedient response via the usual mode of driving. Therefore, military airlift assistance is obtained. The CST’s vehicles and equipment have been designed to be “airlift-able” in one C-5 airplane. If a C-5 is unavailable, two C-17s, three C-141s, or five C-131s can be substituted. Because considerable planning is necessary to successfully conduct an airlift, CSTs periodically participate in airlifts to training sites or conduct static air loading to ensure mission readiness. CST RESPONSE MISSIONS Since their inception in 1998, CSTs have conducted numerous realworld missions. The 2nd CST of New York was the first CST to respond to a terrorist attack when it responded to the 2001 terrorist attacks on the World Trade Center. Statistics provided by the National Guard Bureau indicate that in FY 2008, 70 real-world and 211 stand-by missions were reported by the 53 certified CSTs. When combined with 763 reported internal exercises and an additional 152 training events with first responders, the CSTs were involved in a total of 1,196 events. Notable CST responses throughout the CSTs’ relatively short existence have included providing communication assets and hazard assessments after hurricanes Katrina and Ike, monitoring at presidential inaugurations and the Republican and Democratic national conventions, and assisting at major sporting events, including the World Series, Super Bowl, and Winter Olympics. CST responses have also included conducting debris assessments after the Columbia Space Shuttle disaster, and sample collection and testing during a ricin incident in Nevada and in response to anthrax-contaminated drums in Connecticut. CONCLUSION Since 9-11 much has been done to counteract and respond to terrorism, but more is required. The December 2008 Report of the Commission on the Prevention of WMD Proliferation and Terrorism indicated that, unless further political and strategic preventive measures are implemented, a WMD is likely to be used in a terrorist attack somewhere in the world by the end of 2013.23 Hopefully, that prediction will not come true. Napoleon said, “An army should be ready every day, every night, and at all times of the day and night, to oppose all the resistance of which it is capable.”24 Civil Support Teams were formed specifically to provide a 24/7 response to WMDs. Are they ready? Their training, equipment, and mission history clearly indicate they are. 23. COMM’N ON THE PREVENTION OF WMD PROLIFERATION AND TERRORISM, WORLD AT RISK: THE REPORT OF THE COMMISSION ON THE PREVENTION OF WMD PROLIFERATION AND TERRORISM, at xv (2008), available at 24. THE OFFICER’S MANUAL. NAPOLEON’S MAXIMS OF WAR 20 (Sir George Charles D’Aguilar trans., New York, J.G. Gregory 1861) (Napoleon’s Maxim VII). 4. See Defense Against Weapons of Mass Destruction Act of 1996 , Pub. L. No. 104 - 201 , 110 Stat. 2714 ( codified as amended in scattered sections of 50 U .S.C.). 5. Homeland Defense and Military Support to Civil Authority: Hearing Before the Subcomm. on Emerging Threats of the S. Armed Servs . Comm., 109th Cong . ( 2006 ) (statement of Lt . Gen. H. Steven Blum, Chief, National Guard Bureau), available at 6. Deborah R. Lee , Asst. Sec'y of Def. for Reserve Affairs, Remarks at the Association of Military Surgeons of the United States (Nov . 17, 1997 ), available at speeches/speech.aspx?speechid= 805 . 7. DEP'T OF DEF. TIGER TEAM , DEPARTMENT OF DEFENSE PLAN FOR INTEGRATING NATIONAL GUARD AND RESERVE COMPONENT SUPPORT FOR RESPONSE TO ATTACKS USING WEAPONS OF MASS DESTRUCTION , ( 1998 ), available at (“ The Team's focus on the appropriate, substantive and integrated DOD support model to local, state, and federal government authorities responding to a WMD attack form the basis for this plan .”). 8. Id . (“[T] he plan focuses on filling the void in the State's initial assessment capability and the United States' ability to rapidly facilitate required assistance in excess of the State's capability to respond .”). 9. Id . (“ 18 . Establish at least a partial Rapid Assessment and Initial Detection Element in each State and Territory .”). 10. Commencement Address at the United States Naval Academy in Annapolis, Maryland, 1 PUB . PAPERS 825 (May 22, 1998 ) (“Today [the Defense Department] is announcing plans to train National Guard and reserve elements in every region to address this challenge .”). 11. COMBATING TERRORISM Observations on Federal Spending to Combat Terrorism: Testimony Before the Subcomm . on Nat'l Sec., Veteran's Affairs, and Int'l Relations of the H . Comm. on Gov't Reform, 106th Cong . 10 ( 1999 ) (statement of Henry L . Hinton , Jr., Assistant Comptroller Gen., National Security and International Affairs Division) , available at http:// (“Included in the fiscal year 1999 appropriations is $52 million to establish, train, and equip the first 10 of potentially 54 RAID teams . . . .”). 12. 10 U.S.C. § 12310 (c) ( 2009 ).

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Larry A. Shireley. National Guard Civil Support Teams: A 24/7 Response to Weapons of Mass Destruction, University of St. Thomas Law Journal, 2009,