Ten-Year Counterdrug Technology Plan and Development
Roadmap
Appendix
Agency Comments to OMB Clearance
The Office of Management and Budget (OMB) conducted an interagency clearance of the
ONDCP Ten-Year Counterdrug Technology Plan and Development Roadmap. This appendix contains
the responses received from the interagency clearance with subjective comments. U.S. Coast
Guard, Department of Defense and Central Intelligence Agency concurred with the plan with
minor editorial changes. All of these changes have been made and their comments are not
provided here.
The Departments of Justice, Treasury (including U.S. Customs Service), and Health and
Human Services provided lengthy responses which are included in this appendix in their
entirety. These responses provided both objective and subjective comments. Those objective
comments have been included in the body of the plan or will be addressed in the
implementation process. The Treasury Department response included materials dated February
12, 1998 from Customs Service which had already been addressed in the plan.
May 1, 1998
The Honorable Franklin D. Raines
Director, Office of Management and Budget
Washington, D.C. 20503
Dear Mr. Raines:
Thank you for the opportunity to comment on the Office of National Drug Control
Policy's (ONDCP) draft "Ten-Year Counterdrug Technology Plan and Development
Roadmap" (Technology Plan). The Department of Justice fully supports the
Administration's efforts to encourage and enhance technological capabilities in the
counterdrug area. Furthermore, we applaud the diligent efforts of ONDCP to articulate a
plan of action to improve counterdrug technology over the next 10 years. The Technology
Plan, obviously, demonstrates a great deal of thought and strategic planning on the part
of ONDCP and the participating working groups.
We do, however, have a few overall concerns about the Technology Plan, as it is
currently drafted; additional line-edits are enclosed with this letter. The general
comments are as follows:
The Department of Justice believes that the Technology Plan creates
unsustainable expectations to acquire the listed technological developments, within
current and projected budgetary constraints. We, therefore, suggest that the Technology
Plan include language to explain that the agency budgets will still be reviewed annually
in light of the President's overall budget priorities. We propose that the following
language be included:
"This plan is a long-term strategy to address technological needs in the nation's
effort to reduce the supply and demand of drugs. The resources presented are based upon a
possible strategy, and they do not represent or take into account any department's
priorities regarding funding, nor do they reflect presidential priorities for future
years. The President must weigh his priorities, not only within the criminal justice area,
but also throughout the Government."
-
The Department of Justice believes that the Technology Plan does not
adequately address the evolving nature of counterdrug technology, research, and
development. It is important that the Technology Plan recognizes the need for periodic
re-evaluation and modification, in order to ensure that procurement of technological
innovations are responsive to the realities of current drug trends and patterns.
The Department of Justice believes that the Technology Plan must explicitly
recognize significant ongoing efforts that bear upon the projected forecasts and
predictions (e.g., the multi-agency Counterdrug Intelligence Architecture Review).
The Department of Justice believes that the proposed performance measures must
be viewed within the context of the Department and its component units' performance
measures. For instance, the "output measures of agency technology programs,"
articulated at page 34 of the draft Technology Plan ("number of projects sponsored,
number of deployed systems evolving from agency programs, and number of systems evolving
from CTAC-sponsored projects"), do not seem to be meaningful, useful indicators of
successful research and development programs. Admittedly, generating valid performance
indicators will not be an easy task, especially in light of the uncertainty and lack of
control in the field of technology. Nevertheless, appropriate performance measures should
be developed and determined by the four working group Panels established in the Technology
Plan.
The Department of Justice is concerned that the Technology Plan should not
intrude upon the Operational functions of the law enforcement investigative agencies. To
address this issue, we propose the following language:
" This Technology Plan is offered as a forecast of technological needs and
resolutions and is not intended, in any way, to intrude upon or monitor the operational
planning and work of the law enforcement agencies."
We thank you for the hard work that you, your Office, and ONDCP have devoted to this
worthy endeavor.
Sincerely,
Stephen A. Colgate
Assistant Attorney General For Administration, Department of Justice
Department of Treasury
April 29,1998
COMMENTS ON THE ONDCP DRAFT TECHNOLOGY PLAN
We have reviewed the ONDCP Report on the Ten-Year Counterdrug Technology Plan and have
a number of comments. Customs has also submitted comments under separate cover and
Treasury's Office of Enforcement supports these as well.
The plan appears to have laudable goals. Law Enforcement technologies develop rapidly.
To make an effective assessment of these technologies, law enforcement agencies need
expertise and information. Moreover, successful technology transfer to enforcement
agencies is hampered by disaggregated markets and differing standards. ONDCP and CTAC can
play a constructive and targeted role in helping disseminate and evaluate external
information about available technologies and technology transfer options. For example, the
technology workshops that CTAC plans to organize might prove helpful for a wide variety of
agencies.
AREAS OF CONCERN
Although the goals described above are worthy, we object to certain aspects of the
plan. Below, we provide a brief discussion of these issues.
PERFORMANCE MEASURES: At times, the report appears to assume the existence of an
effective way to quantify achievements gained through technology. We all accept this as
one of a series of important goals; we don't seem to be nearly as close to it as the draft
document suggests. For example, the deployment of a particular technology may coincide
with the adoption of a new enforcement strategy that may not entirely depend on the new
technology. As a result, it is somewhat difficult to ascribe the resulting enforcement
successes to the technology. Conversely, certain technology deployments may have the
potential to improve effective enforcement, but may initially fail to deliver results
because of ineffective coordination, training, or resource deployments. For these reasons,
the plan should indicate caution about the reliability of performance measures to evaluate
enforcement technologies.
COORDINATION VERSUS OVERSIGHT: At times, the plan seems to imply that ONDCP
would extend control over operational and budget matters through CTAC's oversight of the
Science and Technology Committee described in the plan. There are many disturbing
references on this issue, such as the explicit reference to an oversight role for CTAC. As
discussed above, we believe CTAC can play a valuable role in helping to evaluate external
information about enforcement technologies and providing technical assistance in
technology transfer. These valuable roles may be better served if the
"coordination" function is specified more directly to include these functions
and not operational oversight or final authority over technology deployment.
INCLUDING OTHER AGENCIES: In its current form, the plan omits ATF and perhaps
other important agencies from those who should be on the various groups. Although ATF's
core mission is not narcotics enforcement, its role in targeting arms trafficking is
essential.
We look forward to discussing these issues further. Thanks.
U.S. Customs Service
April 29, 1998
APPLIED TECHNOLOGY DIVISION COMMENTS ON
ONDCP REPORT ON TEN-YEAR COUNTERDRUG TECHNOLOGY PLAN
AND DEVELOPMENT ROADMAP (ONDCP-08-A)
The Plan states a "national inspection goal of inspecting 20 percent of the
containers, shipments, and conveyances entering the U.S. for drugs" and implies that
this is a Customs goal (pg. 13). We have previously informed CTAC that this is not
correct; this is not a Customs goal and it is not achievable with the equipment
identified. We believe CTAC initially made this statement based on a mistaken
interpretation of a Customs report and we are concerned that if it remains in the Plan it
really will become an official, and unreachable, national goal imposed on Customs.
The Non-Intrusive Inspection portion of the Plan includes technologies not identified
or supported by the agencies responsible for this segment. The primary example is the
reference to continued effort on PFNA development over the next 10 years (fig. 9, pg. 19).
The Secretary of the Treasury has officially stated that Treasury "has no plans to
acquire an operational PFNA cargo inspection system" and our previous comments to
CTAC on the draft Plan requested that they delete all references to PFNA. We are concerned
that the continued inclusions of PFNA in ONDCP's Plan will be construed as Customs support
for PFNA. Customs believes this is very expensive technology that will not provide needed
benefits.
Because of guidance provided to agency representatives during the preparation of the
Technology Plan, it does not include many agency-specific technology acquisition
requirements. Therefore, the Plan does not include such Customs acquisitions as
sensor-equipped aircraft, marine interdiction vessels, and new radio communications. Since
there is no mention made in the Plan that such requirements were not included, we are
concerned that it could be interpreted as supporting only the included acquisitions,
making it difficult for other initiatives to obtain budget approval.
The Plan deliberately omits any reference to requirements for personnel (pg. 3).
However, we believe it is important to clearly state that some numbers of additional
government and/or contractor personnel will be needed by agencies to utilize the
technology recommended for acquisition, and that the funding for these personnel must
accompany funding for acquisition, operation, and maintenance.
Customs has previously indicated disagreement with many of the time schedules indicated
for deployment decisions on non-intrusive technology items (Fig. 9, pgs. 18-20). We
believe that we will be ready to make many of these decisions much earlier than indicated
and would not want to be obliged to wait until the time periods selected by CTAC or to
continue conducting unnecessary development and evaluation programs.
This Plan is based on the priorities, threats, workloads, and other factors considered
appropriate in 1997, when most of the agency inputs were provided. It must be recognized
that the Plan and the Roadmap will evolve and change over time as such factors change. We
are concerned that this will not be recognized as the Plan is applied by CTAC or others.
One example is the truck x-ray; at the time the plan was developed Customs contemplated
only eight systems; new requirements now indicate that a ninth system is required,
although it is not in today's ONDCP Plan.
The Plan attributes considerable jurisdiction and authority to the IAWG-T (pgs. iv-v).
Much depends on how this group is formed and how CTAC oversight is imposed. Of particular
importance are the determinations of priority, performance, budget guidance, and
allocation of funds. The IAWG-T should not usurp an agency's authority and responsibility
to decide what technology it must acquire to accomplish its mission.
Application of the Plan and Roadmap to budget certification must take into account the
Plan's formulation as an unconstrained set of technology without identification of
specific agency requirements, priorities, timetables, or other needs.
U.S. Customs Service
COMMENTS ON DRAFT 10 YEAR COUNTERDRUG
TECHNOLOGY PLAN AND DEVELOPMENT ROADMAP DATED JANUARY 1998
February 12, 1998
General Comments
The plan does not provide sufficient attention to several issues that were discussed
and considered important by the IAWG-T:
- Development priorities are needed to ensure that any funds eventually provided are spent
on the technology efforts of greatest importance to the law enforcement agencies.
- The importance of acquiring successful technologies versus continued investment in
development needs to be emphasized; without acquisition, there is no value or reason for
development
- GAO requested specific attention to technology transition; this is missing from the
plan. It is not clear, for example, whether the responsibility and authority to decide
whether a specific technology is ready to be implemented rests with CTAC, the lead agency
in each thrust area, or the individual agency that will utilize the equipment.
- There is no recommendation or discussion of how development funds should be provided and
applied to projects; e.g., direct to the lead or individual agency, to the agency through
CTAC, or from CTAC to the development performer.
- There is no confirmation that individual law enforcement agencies are free to conduct
agency-related counterdrug technology developments that may not be included in the CTAC
Plan
Specific Comments
Page 2: In Figure 1.1, add vertical line connecting Goal 4 to the Technology Thrust
box.
Page 3: The paragraph "Wide Area ... Figure 1-2." could be construed to
indicate that the technologies are capable of detecting, inspecting, etc., without human
involvement and will therefore be able to reduce the numbers of agency personnel. Suggest
that the paragraph be changed to indicate that the technologies will support the indicated
functions.
Page 4: Change "principal organizations responsible" to "organizations
principally responsible".
Page 7: In Figure 3-1, clarify whether the data represents seizures reported or
detected by JIATF-East, versus the implied seizures made.
Page 7: The Background paragraph omits any references to the use of aircraft to
transport drugs from South America to the interim or ultimate destinations in Mexico, the
Caribbean, or the U.S. The map in Figure 3-1 indicates the movement of drugs, it does not
indicate the mode. The last sentence of this paragraph limits the role of Customs assets
to actions against targets approaching the U.S.; this is inaccurate, we are as involved
against more distant targets as the other agencies listed.
Page 9: Customs may not have provided input for the procurement of RF Beacons and Tags.
The "# Buy" in Table 3-1 should be increased by 100 to reflect our intentions
for this item.
Page 14: The first paragraph on Scope must be changed to emphasize that NII
technologies also are used by Coast Guard, INS, DEA, and DoD, and in locations outside of
U.S. ports both within and beyond U.S. Borders. The paragraph also must be changed to
state that NII technologies are used to inspect items departing the U.S. for currency and
weapons. The word "violating" in the last sentence is unusual, substitute
"using."
The second paragraph of Scope mentions an "ONDCP" Report to the Congress, but
reference 4 describes it as a Customs Report; please make consistent. This paragraph also
describes a "national inspection goal" of inspecting 20% of items entering the
U.S. This goal is not mentioned in the referenced report and is not a goal proposed by
Customs. If it is an ONDCP or CTAC goal it should be so identified; if not, it should be
deleted from this Plan.
The first Background paragraph includes port-of-entry workload statistics without
indicating the associated time period; the year of the data should be stated. The last
sentence of this paragraph should be revised by deleting "modern, rapid" before
"systems," and inserting "accurate and timely" before
"non-intrusive inspections."
Page 15: Figure 4-1 is attributed to reference 5, a NIDA Report; it should be reference
4.
Table 4-1 is entitled NII System Elements but includes several Physical Examinations
technologies/tools that are intrusive; use "Inspection" instead of NII. Add
"Automated License Plate Readers" under Intelligent Screening.
Page 16: The Operational Requirements paragraph should state that the indicated
Supporting Technologies are only representative rather than a complete listing.
In Figure 4-2, add "Biometrics" under Targeting, change
"Potassium-40" to "Radiation" and add "Piezoelectric" and
"Human Presence Detectors" under Physics Based, and add "Trace
Detectors" under Hand-held Devices.
Page 17: Fourth line on page, change "system" to "capability."
Table 4-2 appears to represent only NII interests of Customs; please ensure that Coast
Guard, INS, DoD, and DEA requirements also are included.
Table 4-2; the data under "O&M $& (M)/" appears to represent
cumulative 5 year O&M costs, not cost per year per system as the column head and
footnote imply. The Greek superscripts are confusing and inconsistent between the table
and the footnotes.
Table 4-2 changes for Customs: for "Targeting/Other" add $1M under R&D
and $2M under Prototype Demo; for "High-E/Rail" change # Buy from 10 to 1; for
"Neutron/Container" reduce Prototype Demo funding from $12M to $3M; change
"NOR" to "NOR/Piezoelectric" under Physics-Based Systems; and for
"Hand-held Devices" add $1M under R&D and $1M for Prototype Demo.
Page 18: Change last sentence of first paragraph by inserting "X-ray and other
inspection systems" for "X-ray systems," and "improving the quality,
intensity, and flexibility" for "speeding up the capability."
Page 19 : The indicated dates for a Deployment Decision for many technologies are
misleading and unacceptable . The Customs Service does not want to have its technology
acquisitions delayed again by recommendations contained in CTAC Reports . We have made our
decision to deploy ATS Systems to seaports and there is no need for the once a year
decision schedule implied by Figure 4-3. Decisions regarding all of the Technology
Assisted Inspections shown on page 19 will be made several years ahead of the indicated
dates, and the time lines indicated are far too long. The 1 MeV and 2-6 MeV System are
prototypes not "testbed evaluations," and the 2-6 MeV Mobile System is not
"dual energy" as used by the industry, it is simply a system capable of two
separate energy levels.
Page 20: Delete all references to PFNA; this technology was not recommended by the NII
thrust group, we do not support a PFNA prototype, and we have already made a deployment
decision. Delete Coded Aperture Neutron Interrogation if it is specific to PFNA. The time
lines for Improved Gamma Ray Detectors and K-40 Detectors should terminate in 1999. There
may be two complementary approaches to Railroad Car Inspection Systems, the first
deployment decision will be made in 1999 and the other by 2000.
Page 23: Table 5-1; add check marks for "Locate/track hostile targets" and
"Mobility" under Interdiction and for "Identify People" under
Information Management.
Page 24: Figure 5-1; add "Non-lethal Vehicle/Boat Stopping" under
Interdiction.
Page 25: It is not clear whether the Table 5-2 entry of "Advanced Conveyance
Interdiction Systems" refers to stopping fleeing vehicles or boats by non-lethal
means, or to some other interdiction technology. If the former, change what it is called
in the Table, and if the latter, add a line for "non-lethal Vehicle/Boat
Stopping" with input provided by INS, Coast Guard, and Customs.
Page 28: Figure 5-2 does not have a section on "Interdiction" to match Table
5-2, and the figure refers to Technology Transfer while the table says Technology
Transition.
Department of Health and Human Services
June 11, 1998
ONDCP report on Ten-year Counterdrug Technology Plan and Development
Roadmap
HHS has the following comments on the revised draft report.
As we have previously pointed out, the report fails to recognize the role of the
Substance Abuse and Mental Health Services Administration (SAMHSA) and the Centers for
Disease Control and Prevention (CDC) of this Department. The report discusses demand
reduction research and technologies, at pp. 25-28. Development of practical applications,
and the transfer and implementation of technology and procedures, are principal parts of
SAMHSA's mission, and SAMHSA administers the majority of federal prevention and treatment
funds. Thus, SAMHSA's role should be recognized in the document. CDC is also deeply
involved in demand reduction research. Specifically, we recommend the following additions:
p.25 ("Scope" section). Following the fourth sentence add: "The
Substance Abuse and Mental Health Services Administration (SAMHSA) facilitates the
adaptation, dissemination and implementation of technologies in the field."
p.25 ("Objectives" section). Following the third sentence, add: "SAMHSA
works with prevention and treatment providers, health care and managed care organizations,
and State and local governments to ensure that the technologies developed by research
institutions are disseminated to the field. SAMHSA leads a departmental initiative on
preventing youth substance abuse. The Centers for Disease Control and Prevention (CDC)
leads another initiative on preventing tobacco use among youth."
p.27 (Figure 12). This figure should be revised to show the role of SAMHSA and of the
dissemination and implementation of counterdrug technologies.
It is not clear whether ONDCP intends this report to focus on technology in a narrow
sense, or whether it intends to cover research more broadly. If the latter, then the
section on "Objectives" in the chapter on demand reduction should be more
specific. We recommend that this section call for (a) research to develop and /or identify
programs with proven effectiveness in reducing the initiation of use of tobacco, alcohol,
and other substances among youth, (b) evaluation to identify the most effective and
efficient means to disseminate these programs, (c) development of guidelines for
implementing programs to prevent youth drug abuse, and (d) evaluation for continual
improvement of programs as they are implemented.
Finally, we have two concerns about the financial aspects of this report. First,
ONDCP should add a line to the Executive Summary, emphasizing that this is not a budget
document. Second, in Table 4, on page 29, the numbers for NIH are too high. This
Department's figures for NIH spending on drug abuse (which include research and
development) are as follows:
FY 1997 |
$499,653,000 |
FY 1998 |
527,175,000 |
FY 1999 |
576,299,000 |
