Avoiding the Rush to Failure: The Judge Advocate’s Role in the Emergency Operations Center
By McKeel, Jennifer A | |
Proquest LLC |
"By failing to prepare, you are preparing to fail."1
I. Introduction
"Extreme weather disasters have hammered
The role of the judge advocate (JA) as a member of the EOC staff requires a broad spectrum of knowledge.6 Waiting until an emergency arises to train, develop, and integrate into the EOC staff is too late. The JA's early and continuous involvement throughout the emergency response process is essential to the successful development and execution of the response plan. This primer discusses the role of the JA as a member of the EOC staff during a natural or man-made disaster; addresses the common legal and ethical issues the JA faces during that response; and presents the best practices a JA can employ if called upon to serve in an EOC.
This primer is not designed to be all-inclusive as to every legal issue that could arise during an emergency response operation. Rather, it delves into several of the more common issues encountered during an emergency response and outlines the steps that should be followed to resolve them and the resources available to assist JAs. Part III specifically identifies areas of importance and surveys issues the JA will encounter during an emergency response. In particular, it focuses on those issues that appear frequently and regularly during the initial emergency response and follow-on recovery support efforts. Throughout, the primer will also address best practices, with an emphasis on ensuring that the JA is an integral member of the EOC staff during the planning, response, and recovery processes.
Before integrating into the EOC staff, JAs must have a basic understanding of the authorities and limitations that apply to domestic support missions when weather-related events occur on or near a military installation. Therefore, this primer begins with an overview of the federal emergency response authorities and a brief discussion of the Defense Support to Civil Authorities (DSCA) mission within the National Response Framework (NRF). This is followed by a review of the
II. Overview of Emergency Response
A. Background
The
B. Emergency Response Authorities
When a disaster strikes on or near a military installation, commanders will frequently seek out ways to provide assistance not only to their own Soldiers living on-post, but also to those who live in the immediate vicinity of the installation. Judge advocates must be involved from the very beginning so they can give relevant, accurate, and timely advice about the commander's authority to act and provide such assistance. While there are many sources from which command authority is derived, every commander has the inherent authority to provide for the safety and welfare of people under his command.9 However, when responding to a weather-related event beyond the installation's gates, commanders must operate within the applicable authorities. Commanders may provide emergency support in accordance with their immediate response authority (IRA), usually lasting no more than seventy-two hours after receiving and reviewing the request for assistance from local authorities.10 A commander's IRA is designed to fill a gap left by local first responders until that aid can be provided by other agencies. Judge advocates can better serve their commanders by having a basic understanding of their commanders' limited authorities and how federal agencies operate within the DSCA framework and under the Stafford Act.
1. The DSCA Framework
The DoD's DSCA mission is not new; in fact, the
The primary reference for DoD support to civil authorities is DoD Directive (DoDD) 3025.18.14 This directive "authorizes immediate response authority for providing DSCA, when requested."15 As previously mentioned, IRA allows DoD commanders to provide assistance to civil authorities for a period of no more than seventy-two hours upon request from civil authorities.16 Other forms of DSCA support must be authorized by the Secretary of Defense, unless approval authority is otherwise delegated, before providing assistance.17 For JAs, this is an opportunity to be proactive in reviewing and determining whether the request complies with the law, conforms to fiscal restraints, and remains within the ethics guidelines. Additionally, JAs must know under which authorities the commander will operate and how that commander will work within the Federal Response Structure throughout the emergency response.18
2. The Federal Response Structure
The current Federal Response Structure, with
During its first years,
Pursuant to the Homeland Security Act of 2002, President
The NRF organizes governmental response to natural and man-made disasters and incidents occurring in
Then in 2011, President
3. The Stafford Act
The Stafford Act aims "to provide an orderly and continuing means of assistance by the Federal Government to State and local governments in carrying out their responsibilities to alleviate the suffering and damage which result from such disasters."37 This assistance is extended upon request, usually from a state governor, when the consequences of a disaster are such that the state or local government cannot adequately respond.38 The Stafford Act defines emergency39 differently from major disaster,40 and depending on the type of declaration, the President's powers can differ greatly.41 Upon issuance of a declaration, DHS may request other federal agencies to deploy to the affected area to assess, monitor, and coordinate the response until the need for assistance is scaled back and transitioned into recovery operations.42 During operations, the Stafford Act provides for immunity from liability for "any claim based upon the exercise or performance of or the failure to exercise or perform a discretionary function or duty on the part of a federal agency or an employee of the federal government in carrying out" its duties, as defined within the Act.43
Generally, assistance under the Stafford Act will not occur until local officials determine that their own resources are not sufficient to address the emergency situation.44 After coordination between State, Federal and local officials, a formal request for a declaration of a major disaster or emergency is made.45 Once that request is received and approved, then the NPS is activated and the necessary response requirements are assigned to the respective federal agencies with
4.
As noted above, DoDD 3025.18 generally allows DoD commanders to provide assistance to civil authorities only upon request from state or local officials. Often, however, emergencies or major disasters will require an installation commander to respond to a request before approval from higher authority can be obtained. When such conditions arise, commanders may use their IRA to "temporarily [employ] the resources under their control, subject to any supplemental direction provided by higher headquarters, to save lives, prevent human suffering, or mitigate great property damage within
The type of support the commander may provide will vary based on the situation. However, any support provided must not put the commander or his command at risk of subjecting civilians to the use of military power in violation of law, such as the Posse Comitatus Act (PCA).50 The PCA, as implemented through statute and DoD directives, restricts military personnel in federal status from being directly involved in civilian law enforcement activities, unless authorized by the Constitution or an act of Congress.51 When commanders operate within the confines of domestic authorities, the PCA will limit their ability to support local law enforcement agencies.52 These limitations also affect which resources commanders can provide to local first responders during an emergency. Additionally, they will greatly limit the involvement that military personnel in federal status will have with the local populace in support of civil law enforcement.
Despite its limitations, requests by local authorities are commonly made to use military personnel in ways that may violate the PCA. For example, when a massive tornado hit
Once the commander's IRA has expired and the NRF is in place, any further requests from local authorities should be routed through the Defense Coordinating Officer (DCO).56 "The DCO serves as the
C.
To maintain situational awareness on day-to-day operations for the installation or senior commander, major military installations will have an established operations or command center. Often these command centers (commonly referred to as Installation Operations Centers (IOCs)) are minimally manned and only become fully operational during a training exercise or in response to an event on the installation. The installation's
During an emergency response and recovery mission, the IOC will establish a temporary EOC for the duration of the mission. While the IOC is a flexible organization, setting up a separate command center should be considered when an emergency arises; allows the staff working within the EOC to focus their efforts on the emergency response and recovery effort, while the IOC continues its normal operations.59 In that case, a decision as to which commander will be in charge of each operations center should be determined well in advance to avoid confusion once the response effort is under way.60
Installation IOCs will establish their own battle rhythm, with the staff participating in the working groups are responsible for planning, writing, and disseminating the orders the installation depends upon to operate. The JAs working in the IOC often attend these working groups and participate in the Military Decision Making Process (MDMP).61 Judge advocates can provide valuable input by "preparing legal estimates . . . writing legal annexes . . . and reviewing plans and orders."62 Ultimately though, the JA's "primary responsibility is to identify legal considerations (authorities, restraints, and constraints) . . . early in the planning process" to avoid developing a plan that is not legally feasible.63 Judge advocates who remain engaged in these working groups can work proactively with the staff to prevent potential legal issues early in the planning process. Collaborating early and often in the MDMP and providing sound legal advice and alternatives will go far in building a JA's credibility with the IOC staff and the commander.
When an emergency does occur, the JA who can "work proactively to promote the mission" and is knowledgeable as both a Soldier and a lawyer64 will be sought out to support the response and recovery operation. The primary mission of the EOC is to provide a centralized location for the coordinating effort during emergency response and to promote efficient and effective management of the current situation.65 The EOC receives information from within the operational area to create a common operating picture for those responding to the event.66 This allows for the collaborative effort of the staff sections to successfully and efficiently address issues as they arise, while coordinating the flow of information and resources to those in the field.67 However, before the EOC's staff can respond to any emergency, a plan must exist, and the staff must be trained and prepared to execute that plan.
III. Emergency Response and the
A. Preparation is Key
Failing to prepare is preparing to fail68 and this is no less true than when an installation is faced with responding to a crisis without having developed a sufficient response plan. Certainly, no one expects to be affected by a wildfire, tornado, or other disaster, but facing an emergency without a plan can result in higher losses of life, limb, or property. "A successful organizational preparedness program needs: a clear vision; actionable objectives and goals; defined deliverables and timelines; regular reviews; [and] identify potential obstacle [sic] and challenges." 69 These plans are developed by the working groups using the MDMP and require buy-in from the commander.
Once the commander approves the plan, it must be continually reviewed, practiced, and reassessed to ensure that the risks are identified, contingencies are considered, and potential pitfalls are discovered and remedied. Judge advocates play a crucial part in this process by reviewing the plan for completeness and legality. However, to reach that level of expertise, credibility, and flexibility, JAs must be provided the opportunity to receive proper training and given access to the necessary resources and support.
1. Training for the Operational Law Attorney
The OSJA is responsible for training its JAs and ensuring that they are properly resourced. Judge advocates assigned to an IOC as operational law attorneys would benefit from a training program that focuses on "[S]oldier skill proficiency, familiarity with the core legal disciplines for military operations, and an understanding of the judge advocate's role in the [operational law] mission."70 Specifically, training should focus on the MDMP and domestic operations. Training can be obtained from on-the- job experience and reaching out to colleagues, as well as, attending office or installation-level professional development programs.
Additionally, JAs can receive formalized continuing legal education at a military legal institution, such as the
2. Exercising the Plan
Training exercises allow the staff to practice operational standards, to test and refine plans, and to identify lessons learned in a controlled environment. Exercises also allow commanders to determine whether their intent was met and to evaluate overall force readiness and mobilization preparedness.73 Participating in these exercises provides JAs a chance to see the plan in action and to discover any potential shortfalls that must be fixed before execution. It is also an opportunity for JAs to test their knowledge and assess their level of preparation. Further, the exercise will give them a chance to discover any gaps in support that may cause significant issues during an actual emergency and determine whether drafting certain documents or agreements beforehand could fill those gaps.74
3. Getting All Your "Docs" in a Row
It is always good practice for newly assigned JAs to review the existing plan and any existing MOAs. Taking the time before an emergency to determine whether the existing MOAs are adequate for the response required or whether there is a gap in needed support is crucial in avoiding unnecessary stress and a delay in response during an emergency event. One document to consider updating or, if absent, drafting, is a Mutual Aid or Assistance Agreement. As authorized by statute, MAAs allow agency heads (e.g., installation or division commanders) with the duty to provide fire protection for any property of
Another recommendation is to create an MOA between the installation and local facilities for use as shelters-in- place. This may quickly become necessary when an emergency requires the installation commander to issue evacuation orders for individuals residing on the installation. To save time and to avoid missing a crucial element in drafting the MOA, JAs should consider introducing this course of action early in the planning phase of the MDMP. Taking the time to develop the MOA to ensure that it addresses specific needs (e.g., size of population that may be displaced, proximity to installation, contingency locations, etc.) will pay dividends in the event the need arises.80
In the summer of 2012, encroaching wildfires threatened
Judge advocates should also consider drafting a template for evacuation orders that can be used, should the need arise, during the course of the emergency response. While evacuation orders may initially be given verbally by the commander, they will need to be reduced into written orders as soon as practicable. At a minimum, the written evacuation orders should include the basis for the order, the effective date, how long it will remain in effect, who is being evacuated and from what location, maximum safe haven distances, and funding cites.82 Having a template prepared beforehand will help avoid the potential omission of critical information and ensure timely dissemination of the orders to facilitate efficient submission of travel vouchers.83 When the emergency has passed and evacuation is no longer required, the commander must terminate the order to effectively stop the entitlements afforded to the evacuees. Judge advocates can assist in this process by tracking the issued orders and reminding the commander to terminate them when appropriate. Finally, JAs should consider creating a quick reference guide, which could include sample MOAs, claims cards for personal property damages, and information papers discussing common issues or lessons learned.84
B. Common Issues
While each installation's response to an emergency is unique, the issues encountered will often be similar. Therefore, it is critical for the EOC staff, including the JA, to keep an on-going log of issues and recommended solutions throughout any event, whether it is a training exercise or a real event. Taking the time to capture these issues85 and compiling them into an AAR will pay significant dividends during the planning and execution of future emergency response missions. These AARs are an excellent source for spotting potential issues during the planning phase and can be a quick resource for addressing any issues during an emergency response. A review of the most recent AARs covering the military's response to natural and man-made disasters reveals similar issues across the spectrum of disciplines. In general, the most common issues involved interagency coordination, ethics and administrative law concerns, and questions relating to intelligence oversight.
1. Interagency Coordination
Most emergency responses require the assistance of the local first responders, utility companies, and local and state emergency management agencies. If a national emergency or disaster is declared, then federal agencies deploy as well, with DHS/
During the recent responses to the
Similarly, the JAs working the
2. Accepting Donations
Emergencies always seem to bring the best out of people, and while the outpouring of support is appreciated, JAs will have to address the issues associated with donations of goods, money, and services. Gift offers will raise many ethical concerns, including appearance issues, gift value limits, and proper disposal of surplus donations.94 But no matter the type of gift or donation, JAs must remain mindful that the emergency situation does not change the gift acceptance analysis.95
Developing a plan to address these issues and having it in place in advance will free up the JA to focus on more pressing issues during the response. One possible solution is to develop an MOA with the installation's Morale, Welfare, and Recreation (MWR) or local non-federal entities such as the
3. Collecting Intelligence and Intelligence Oversight
While a full analysis of intelligence oversight is beyond the scope of this paper, JAs must at least be able to spot the potential issues involved with using intelligence assets during domestic operations. "Judge advocates must recognize that collecting domestic intelligence by necessity entails collecting information on U.S. persons."97 Due to its complexity, intelligence oversight questions should not be answered without full consideration of the existing authorities. At a minimum, JAs should carefully review all requests by local authorities or their commanders which include (or which may include) the use of intelligence assets and components to gain situational awareness of the space in which they will be operating.98 Obtaining this information may result in the collection of information on U.S. persons, which could violate the intelligence oversight rules.99 Judge advocates should familiarize themselves with these rules and the framework for reviewing requests.100 Having a grasp of the basic framework of intelligence collection law and procedures will provide a starting point from which to analyze the issue, and help JAs recognize the request should be forwarded to a higher or outside authority for review and approval.101
IV. Conclusion
The EOC can be a formidable place for any JA unfamiliar with its dynamic mission and shifting requirements. While intimidating at first, JAs can quickly integrate into the EOC staff with a well-stocked tool kit and a general understanding of the common issues that may develop. The middle of an emergency is not the time for on- the-job training; early involvement and preparation are critical to successful integration with the Plans and Operations staff. While not always practicable or available, formal DOMOPs and DSCA training is the best means of receiving the most current information in this area of law. Additionally, JAs should familiarize themselves with the operations center and its staff, as well as participate in the planning process and installation training exercises whenever practicable. Maintaining that presence will allow the JA to recognize, address, and confidently resolve legal concerns before they become significant issues during an emergency.
Judge advocates have proven to be crucial members of the EOC staff, as evidenced during past events. Judge advocates assisted with the development of evacuation orders and dealt competently with the potential fiscal issues, oftentimes coordinating with interagency counterparts. Their advice ensured a smooth transition from the initial DoD assistance to a fully developed federal response. Looking to the lessons learned from past events further allows JAs to quickly identify potential areas of dispute and give timely relevant advice. So next time you are called upon to serve in the EOC, take advantage of those lessons learned and available training, insert yourself early and often in the day-to-day operations of the IOC, and engage the IOC staff during the planning process to avoid potential legal pitfalls. Do not rush to failure by failing to prepare.
1 BRAINY QUOTE, http://www.brainyquote.com/quotes/quotes/b/benjaminfr 138217.html (last visited
2
3 Id.
4 Disaster Declarations for 2012, FEMA.GOV, http://www.fema.gov/ disasters/grid/year/2012?field_disaster_type_term_tid_1=All (last visited <chron>Mar. 15, 2014).
5 Disaster Declarations for 2013, FEMA.GOV, http://www.fema.gov/ disasters/grid/year/2013?field_disaster_type_term_tid_1=All (last visited
6 Judge advocates (JAs) assigned as operational or administrative law attorneys might be better suited to support the emergency response mission since they are familiar with the issues, they are integrated into the staff sections, and they are involved in the mission planning. Further discussion can be found in Part II.C.
7 U.S. DEP'T OF DEF., STRATEGY FOR HOMELAND DEFENSE AND DEFENSE IN SUPPORT OF CIVIL AUTHORITIES 1 (
8 CTR. FOR LAW & MILITARY OPERATIONS, THE JUDGE ADVOCATE GEN.'S LEGAL CTR. & SCH.,
9 See U.S. CONST. art. I, § 8 (granting
10 U.S. DEP'T OF DEF., DIR. 3025.18, DEFENSE SUPPORT OF CIVIL AUTHORITIES (DSCA) para. 4.g-4.g.2 (
11 DOMOPS HANDBOOK, supra note 8, at 3.
12 Id. While not within the scope of this primer, the
13 Id. at 4.
14 DSCA, supra note 10.
15 Id. para. 1.e.
16 Id. para. 4.g.2. The commander's
17 Id. para. 4.d.
18 THE FED. EMERGENCY MGMT. AGENCY PUB. 1, THE FED. EMERGENCY MANAGEMENT AGENCY 30 (
19 Id.
20 Id. at 3 (providing a succinct history of the creation and development of
21 Id. at 6. Examples include the National Weather Service Community Preparedness Program, the
22 Id. at 6.
23 Id. at 7.
24 Id. at 8.
25 Id.
26 Exec. Order No. 12,656, 3 C.F.R. 585 (1988).
27 Id.
28 DOMOPS HANDBOOK, supra note 8, at 9-10 (referencing The Homeland Security Act of 2002, Pub. L. No. 107-29, 116 Stat. 2135 (2002) (as amended) This legislation established the
Id. Note that Exec. Order No. 13,228, 66 Fed. Reg. 51,812 (
29 HOMELAND SECURITY PRESIDENTIAL DIR. 5, MANAGEMENT OF DOMESTIC INCIDENTS 229 (
30 The Homeland Security Act of 2002 § 502, Pub. L. No. 107-296, 116 Stat. 2135 (2002) (as amended).
31 U.S. DEP'T HOMELAND SEC., NATIONAL RESPONSE FRAMEWORK (2d ed.
32 PRESIDENTIAL POL'Y DIR. 8, NATIONAL PREPAREDNESS (
33 NRF, supra note 31.
34 Id.
35 Id.
36 The Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. §§ 5121-5206 (1974) (as amended by the Post-Katrina Emergency Management Reform Act of 2006, Pub. L. No. 109-295, 120 Stat. 1355 (2007), and the Sandy Recovery Improvement Act of 2013, Pub. L. No. 113-2, 127 Stat. 4 (2013)) [hereinafter Stafford Act].
37 See id. § 5121.
38 Id.
39 An emergency declaration by the President means that "[f]ederal assistance is needed to supplement State and local efforts and capabilities to save lives and to protect property and public health and safety, or to lessen or avert the threat of a catastrophe in any part of
40 A major disaster is defined as "any natural catastrophe, . . . or, regardless of cause, any fire, flood, or explosion, in any part of
41 Unlike a major disaster declaration, "emergency assistance is more limited . . . and total assistance may not exceed
42 Overview of Stafford Act Support to States, FEMA.GOV, available at http://www.fema.gov/pdf/emergency/nrf/nrf-stafford.pdf (last visited
43 Stafford Act, supra note 36. See Appendix A (Stafford Act Process) (illustrating the process used to request and provide support in accordance with The Stafford Act).
44 Overview, supra note 42.
45 Id.
46 Id.
47 DSCA, supra note 10, para. 4.g.
48 Id. para. 4.e. Judge advocates should evaluate the request using the factors: cost, appropriateness, risk, readiness, legality, and lethality, to determine whether the request fits within the guidance found in DoDD 3025.18, stating that the plan "shall be compatible with . . . the National Incident Management System . . . or
49 Id. para. 4.g.1.
50 The Posse Comitatus Act, 18 U.S.C. § 1385 (2011).
51 Id. The Posse Comitatus Act (PCA) only restricts the
52 See Appendix B (PCA Applicability) (providing an overview of the applicable statutory and regulatory exceptions to the PCA).
53 CTR. FOR LAW & MILITARY OPERATIONS, THE JUDGE ADVOCATE GEN.'S LEGAL CTR. & SCH.,
54 CTR. FOR LAW & MILITARY OPERATIONS, THE JUDGE ADVOCATE GEN.'S LEGAL CTR. & SCH.,
55 Id. at 11; TINKER AFB TORNADOES AAR, supra note 53, at 7.
56 DOMOPS HANDBOOK, supra note 8, at 21.
57 Role of the Federal Coordinating Officer in Disaster Operations, available at http://www.fema.gov/region-ii-federal-coordinating-officers- and-defense-coordinating-officers (last visited
58 FORT CARSON WILDFIRES AAR, supra note 54, at 8.
59 Id. at 15-16.
60 Id. (discussing how during the response to the 2012 Colorado Wildfires,
61 U.S. DEP'T OF ARMY, DOCTRINE PUB. 5-0, THE OPERATIONS PROCESS para. 32 (
62 U.S. DEP'T OF ARMY, DOCTRINE PUB. 1-04, LEGAL SUPPORT TO THE OPERATIONAL ARMY para. 5-20 (18 Mar. 2013).
63
64 Id. at vi.
65 Fusion Centers and Emergency Operations Centers, U.S. DEP'T OF HOMELAND SECURITY, http://www.dhs.gov/fusion-centers-and-emergency- operations-centers (last visited
66 Id.
67 Id.
68 BRAINY QUOTE, supra note 1.
69 Ready Responder, READY.GOV, available at http://www.ready.gov/ responder (last visited
70 Major
71 THE JUDGE ADVOCATE GEN.'S LEGAL CTR. & SCH.,
72 Two helpful resources for JAs with access to a CAC-enabled computer are MilSuite's and the
73 U.S. DEP'T OF ARMY, REG. 350-28, ARMY EXERCISES para. 2-1 (9 Dec. 1997).
74 Id. para. 4-11.
75 CLAMO, https://www.jagcnet.army.mil/CLAMO (last visited
76 FORT CARSON WILDFIRES AAR, supra note 54, at 3, 13. See also TINKER AFB TORNADOES AAR, supra note 53, at 7.
77 Preparedness, FEMA.GOV, available at http://www.fema.gov/ preparedness-0 (last visited
78 42 U.S.C.A. § 1856a (West, Westlaw through Pub. L. No. 113-72 (excluding Pub.
79 Id.
80 FORT CARSON WILDFIRES AAR, supra note 54, at 4, 12.
81 E-mail from Captain
82 FORT CARSON WILDFIRES AAR, supra note 54, at 12-13.
83 Evacuation entitlements for all military and civilian personnel and their dependants can be found in the JOINT FED. TRAVEL REG., vol. 1, (Uniformed Personnel) (C297) (2012) and the JOINT TRAVEL REG., vol. 2 (Dep't of Def. Civ. Personnel) (C551) (2012).
84 This list is not all inclusive of the documents that could be drafted in support of an emergency preparedness plan. Instead, it is meant to act as a starting point for JAs who are reviewing the existing agreements or who are supporting the planning process for their installations' emergency preparedness plan. An overview of Disaster Claims Preparedness and links to helpful claims resources can be found at JAGCNET, https://www. jagcnet.army.mil/Sites/jagc.nsf/homeDisplay.xsp?open&documentId=A2A CB9CDEA393C69852579CF004FDA7D (last visited
85 Often, staff judge advocate offices will incorporate these lessons learned into quick reference guides and information papers. Additionally, CLAMO will develop an AAR, which can found in its document repository. Finally, JAs can reach out to their peers at other installations as well as within their own offices.
86 DOMOPS HANDBOOK, supra note 8, at 34-35.
87 TINKER AFB TORNADOES AAR, supra note 53, at 6-7.
88 Id.
89 Id.
90 FORT CARSON WILDFIRES AAR, supra note 54, at 7.
91 Id.
92 Id.
93 Id.
94 TINKER AFB TORNADOES AAR, supra note 53, at 9.
95 A great resource for ethics and administrative legal issues is the General Administrative Law Deskbook, which can be found online at https://www.jagcnet2.army.mil/Sites%5C%5Cadministrativelaw.nsf/0/C288 1C97920E63AF85257B2E0071458C/%24File/General%20Administrative %20Law%20(GAL)%20Deskbook.pdf (last visited
96 FORT CARSON WILDFIRES AAR, supra note 54, at 4.
97 DOMOPS HANDBOOK, supra note 8, at 164.
98 Id.
99 See Exec. Order No. 12,333, 3 C.F.R. 1981 Comp. 200 (1981) (as amended by Executive Orders 13,284 (2003), 13,355 (2004), and 13,470(2008)); see also U.S. DEP'T OF DEF., REG. 5240.1-R, PROCEDURES GOVERNING THE ACTIVITIES OF DOD INTELLIGENCE COMPONENTS THAT AFFECT U.S. PERSONS (
100 See DOMOPS HANDBOOK, supra note 8, ch. 9 (providing an overview of the Intelligence Oversight rules).
101 See CTR. FOR LAW & MILITARY OPERATIONS, THE JUDGE ADVOCATE GEN.'S LEGAL CTR. & SCH.,
102 Overview of Stafford Act Support to States, FEMA.GOV, available at http://www.fema.gov/pdf/emergency/nrf/nrf-stafford.pdf (last visited
103 PowerPoint Presentation of Major
104 DOMOPS HANDBOOK, supra note 8, at 37.
Major
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