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North American Defence And Security In The Aftermath Of 9/11

by Lieutenant-General Rick Findley and Lieutenant General Joe Inge

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Aim

The purpose of this article is to provide the reader with a brief background on Canada and the United States (CANUS)1 relationships, and to also provide a snapshot of the progress that the Bi-national Planning Group (BPG) has made towards enhanced military cooperation.

Background

Canada and the United States fought as partners in two world wars, the Korean War, Desert Storm, the Balkans, and, most recently, in Afghanistan. Our participation in these conflicts as well as our membership in the North Atlantic Treaty Organization has focused on joint and combined operations in overseas theatres. We have been partners in diplomacy and in the defence of North America, planning and acting within the framework of the Ogdensburg Agreement (1940), the North Atlantic Treaty (1948), and the North American Aerospace Defence (NORAD) Agreement (1958). Our two nations have a long history of cooperation that has resulted in the economic prosperity, safety and freedom of our people.

In the 10 years following the Persian Gulf War, there were numerous terrorist attacks against the United States, including the initial World Trade Center bombing in 1993, a car bombing in Riyadh, Saudi Arabia in 1995, a truck bombing in Dhahran, Saudi Arabia in 1996, two United States Embassy bombings in Kenya and Tanzania in 1998, and the bombing of the USS Cole near Yemen in 2000. Subsequently, force protection was enhanced in all overseas locations, and law enforcement officials investigated each of these incidents.

Throughout the 1990s, and extending into the first part of the present century, the Canadian Department of National Defence (DND), like the U.S. Department of Defense (DoD), was focused on external, strategic threats to our respective countries. During this same period, the post-Cold War peace dividend generated military budget and personnel cuts, base closures, and a military focused on an ‘away game’ in the Balkans and other distant theatres.

Flag United States

  • Champion aspirations for human dignity
  • Strengthen alliances:
    • Defeat global terrorism
    • Prevent attacks
  • Partner to defuse regional conflicts
  • Prevent threats of WMD
  • Ignite global economic growth
  • Expand democratic development
  • Develop agendas for cooperative action
  • Transform security institutions

– National Security Strategy for
the United States of America,
September 2002

Flag Canada

  • Protect Canada and Canadians at home and abroad
  • Ensure Canada is not a base for threats to allies
  • Contribute to international security
  • Measures:
  • Build and Integrated Security System
    • Threat Assessment
    • Protection and Prevention
    • Consequence management
  • Increase intercollection capabilities
  • Marine security cooperation with US
  • Build on Smart Border Agreement

– Securing an Open Society: Canada’s
National Security Policy, April 2004

Figure 1: NSS and NSP

The synchronized terrorist attacks on 11 September 2001 made it clear that the Atlantic and Pacific oceans no longer insulate our people from foreign aggression. Although the Canadian homeland was not directly attacked, the terrorists had temporarily achieved one of their goals – to damage North American economies by targeting the United States.

Canada and the US have one of the most significant trade relationships of any two nations on earth, with $CDN 1.8 billion in trade flowing between our borders each and every day.2 Eighty-five per cent of Canadian exports go to the U.S., and 25 per cent of U.S. exports go to Canada. Additionally, 39 American states consider Canada to be their top export destination. Hence, the economic impact of the 9/11 attacks was felt by both our nations, at the municipal, state, provincial and federal levels. For instance, increased border security resulted in a 30-mile queuing of trucks at the Canada-US border immediately after the attacks, and this depleted inventories that relied upon ‘just-in time’ delivery of supplies. Although the impact on our economies was temporary, it became clear that an attack on one of our nations affects the safety, security, economy and well-being of the other.

The 9/11 attack demonstrated that new strategies were needed to protect our homelands and to strengthen our alliance and partnership to meet challenges to our common interests.3 The Canadian and US governments recognized that, by working together, we could meet the challenges of this new threat environment, where homeland defence and homeland security (HLS) had become top priorities for our nations, as articulated in both the Canadian National Security Policy (NSP) and U.S. National Security Strategy (NSS).4

Recognizing that one must be able to fight the ‘away game’ and the ‘home game’ simultaneously, President Bush launched the global war on terror with Operation Enduring Freedom in October 2001. Similarly, Canada launched Operation Apollo in Afghanistan, contributing significant air, land and maritime forces through the deployment of 2300 men and women. As part of the UN International Security Assistance Force (ISAF) in Afghanistan, Canada has been the lead nation for the ISAF’s Kabul Multinational Brigade, providing the Commander as well as the Deputy Commander of the ISAF from 2003 through 2004. The ‘home game’ has also changed significantly. Prime Minister Martin emphasized in the NSP that:

“The September 11 attacks demonstrated the profound effect an event in the United States could have on Canadians and the need to work together to address threats ... Canada is committed to strengthening North American security as an important means of enhancing Canadian security.”5

Similarly, President Bush described the CANUS relationship as vital, emphasizing: “We share the same values: freedom and human dignity and treating people decently.”6 As the President further elaborated in the NSS: “There is little of lasting consequence that the United States can accomplish in the world without the sustained cooperation of its allies and friends in Canada.”7

Hence, both leaders have articulated their visions of a safe and secure environment for our people in the NSP and NSS, using the principles contained in Figure 1. Additionally, during their recent meeting in Ottawa, Prime Minister Martin and US President Bush issued the following joint statement:

“Canada and the United States will work to ensure the coherence and effectiveness of our North American security arrangements by:

  • improving the coordination of intelligence-sharing, cross-border law enforcement and counter-terrorism;

  • taking further steps to secure the Canada-US border while improving the flow of legitimate traffic, through investments in border infrastructure and a land pre-clearance initiative;

  • combating human trafficking;

  • increasing the security of critical infrastructure, including transportation, energy, and communications networks;

  • ensuring the security and integrity of passports issued by each country, consistent with our Consular Understanding of January 13, 2004; and,

  • working towards renewing the NORAD agreement and investigating opportunities for greater cooperation on North American maritime surveillance and maritime defence.”8

We deduce that embedding these principles into new political agreements and enabling mechanisms would lead to the following end state:

Enhanced defence and security of Canada and the United States, such that our mutual societies continue to prosper in an environment where our citizens are, and feel, free and safe. Before the 9/11 terrorist attacks, no single agency in Canada or the United States was in charge of security. This changed when President Bush created the Department of Homeland Security (DHS) and Prime Minister Martin created Public Safety and Emergency Preparedness Canada (PSEPC). Both agencies now have oversight of homeland security, and both are the federal lead agencies for emergency responses within our respective borders.

Additionally, the Smart Borders Declaration was signed by Canada and the United States in December 2001 to secure the movement of people and goods between our two nations. Border Security was included as a Smart Borders initiative to ensure the integration of biometrics, the science of identifying a person on the basis of physical or behavioural characteristics in border and immigration systems, to enhance the design and issuance processes of travel and proof-of-status documents, and to validate the identity of travellers at ports of entry.

The threat environment has expanded from a strategic, nuclear, symmetrical threat from bombers, ICBMs, and air-or-sea-launched cruise missiles, to a continuing symmetrical threat in addition to an emergent asymmetric threat, focused across all domains, borders and agencies. Accordingly, our political leaders recognized a need to transform the military for a new ‘home game’. United States Northern Command (USNORTHCOM) was established to assume responsibility for the defence of the US homeland, and this new Command was tasked to provide military assistance to civil authorities (MACA).

Canada and the United States have conducted integrated air operations under the aegis of NORAD for almost five decades. For years, NORAD was primarily focused upon the Soviet Union and other external threats, and while perceived external threats remain, NORAD has also refocused upon the potential for threats from within. However, in this age of trans-national terrorism, non-state actors now have the destructive capacity that once belonged only to nation states.9 Therefore, Canadian and US leaders have determined that it is also critical to study North American security and defence in other domains. One option may prove to be adding new roles and missions to the successful NORAD construct.

Portrait
Lieutenant-General Rick Findley, Canadian Forces

The Bi-national Planning Group (BPG)

As a result of a change in the threat environment, and at the request of the Minister of Foreign Affairs Canada and the Secretary of State of the United States of America, the BPG was created to study the future of CANUS cooperation in broadening bi-national defence arrangements for North American security.10 The Canadian-US Agreement for Enhanced Military Cooperation (December 2002) gave the BPG a multi-faceted mandate to determine the optimal defence arrangements needed in order to prevent or mitigate threats or attacks, as well as respond to natural disasters or other major emergencies in Canada and the United States. To ensure that the perspectives of all stakeholders were considered, the BPG was composed of members from the Canadian Forces and American representatives from both NORAD and USNORTHCOM.

The BPG initiated a formal analysis on enhanced military cooperation in order to determine the changes needed in concepts, policies, authorities, organization and/or technology. More specifically, the BPG is active in the following areas:11

  • the conducting of reviews of all existing Canada-U.S. defence plans and protocols... with a view toward improving North American land and maritime defence, as well as military support to civil agencies in Canada and the United States;12

  • the preparation of bi-national contingency plans to respond to threats, attacks, and other major emergencies in CANUS;13

  • the maintenance of awareness of emerging situations through maritime surveillance activities...to include assessment of maritime threats, incidents, and emergencies to advise and/or warn both Governments;14

  • the designing of and participation in exercises;15

  • the planning of and participation in joint training programs;16 and

  • the establishment of coordination mechanisms with relevant Canadian and US federal agencies.17

Portrait
Lieutenant General Joe Inge, US Army

Review of CANUS Plans and Protocols

The BPG investigated CANUS plans and agreements associated with Canadian National Defence Headquarters (NDHQ), NORAD and USNORTHCOM, as well as applicable bi-national memorandums or agreements impacting upon the Canadian Forces (CF), Transport Canada, US Transportation Command, US Pacific Command, US Joint Forces Command, the former US Atlantic Command and the US Army Forces Command.

The BPG then created a Bi-national Document Library containing treaties, agreements, Memorandums of Understanding and Memorandums of Agreement between Canada and the United States. This ‘searchable’ on-line library, containing a variety of directives and regulations from both nations, more than 540 documents in total, will be of great assistance to planners on both sides of the border working on bi-national and cross-border issues. Users may search the electronic library by Key Word, Category, Title, Classification and BPG Document number. The library also contains links to other on-line research sites, such as the Canadian Forces Virtual Library and US DoD Documents.18 This is no small accomplishment, since a single repository of bi-national plans, policies and agreements did not previously exist.

After a thorough review of these documents, our researchers identified the necessity to develop strong relationships with key Canadian DND and US DoD entities, as well as other government departments or agencies (OGD/OGA) in order to ensure the defence and security of our homelands.

Prepare CANUS Plans

Canadian and American planners have been creating bi-national defence plans since the Ogdensburg Agreement, struck between our two nations in 1940. The first plan created was focused upon countering a potential German invasion of North America, while subsequent planning focused upon the Japanese threat that emerged in 1941. As a result of the 9/11 attacks, NATO’s Article V was invoked for the first time, but much of the North American war planning was no longer current, due to benign neglect. Our subsequent review of the CANUS family of plans determined that the Basic Security Document (BSD), Land Operations Plan (LANDOP), Maritime–East Operations Plan (MAREASTOP) and Maritime–West Operations Plan (MARWESTOP) were all out of date.

Graphics
Figure 2. BPG Planning Process19

These plans did not adequately address asymmetric threats, and many of the organizations contained within these plans no longer existed. In addition, although the BSD and the LANDOP addressed military support to civil authorities, neither addressed the newly created Department of Homeland Security and Public Safety and Emergency Preparedness Canada roles as lead federal agencies for homeland security. Therefore, the BPG followed a deliberate planning process.

First, BPG planners focused upon the Canadian NSP and the 1994 Canadian White Paper on Defence, then compared both documents to the U.S. NSS and National Military Strategy, as well as the Theater Security Cooperation Guidance. The planners also reviewed the Joint Strategic Capabilities Plan (JSCP), the Unified Command Plan and Forces For Unified Commands (Forces For) to ensure that our analysis was compliant with these key directives.

The result of this review initiated a revision of the BSD, and it is being further developed between NDHQ and USNORTHCOM staffs. The revised BSD provides strategic level guidance for the planning of bi-national operations for the defence of the CANUS region, as well as bi-national military support to civil authorities.20 The draft document now incorporates over-arching guidance that was derived from the Canadian Prime Minister’s NSP, the 1994 Canadian White Paper on Defence and the US President’s NSS, as well as guidance gleaned from other critical DND and DoD documents.21 Hence, the BSD is similar in scope to the US Joint Strategic Capabilities Plan, as it is intended to provide strategic guidance from the Canadian Chief of the Defence Staff (on behalf of the Minister of National Defence) and US Chairman of the Joint Chiefs of Staff (on behalf of the Secretary of Defense), to the CANUS operational commanders.

The BPG planners also compared the Canadian Forces Operational Planning Process (CF OPP) and the US Joint Operations planning and Execution System (JOPES), finding commonality in content, with minor deviations in format. Using CF OPP/JOPES, a new military-to-military support to civil authorities plan was developed to facilitate bi-national consequence management.

Finally, the BPG has undertaken to create a strategic concept plan for the joint and combined defence of North America, contained within a Combined Defence Plan (CDP). The CDP will capture valuable information, processes and procedures from the former LANDOP, MAREASTOP and MARWESTOP plans, but will also add a newer focus on asymmetric threats, as well as joint and combined responses designed to deter, detect or defeat those threats bi-nationally.

Maritime Domain Awareness

The Honorable Paul McHale, the U.S. Assistant Secretary of Defense for Homeland Defense, and Admiral (Ret’d) James Loy, the US Deputy Secretary of the Department of Homeland Security, have created a Maritime Domain Awareness (MDA) group that has successfully tackled many of the tough issues of MDA, defined as follows:

MDA is the effective understanding of anything in the maritime environment that could adversely affect CANUS security, safety, economy or environment.22

MDA is greater than mere surveillance since it is very broad in scope and geography, it acts as an enabler for all maritime missions, and it must be a fully integrated effort for local, state, provincial and federal governments, as well as the private sector. Since the shipment of commodities or passengers in the maritime sector comes from other modes of transportation, there are many inter-dependencies crossing this domain. Hence, MDA must be viewed as an end-to-end international transportation problem as well as a subset of Global Domain Awareness (GDA), which is defined as follows:

GDA is the knowledge in all environments, of anything that could adversely affect CANUS security, safety, economy, or environment.23

Soldiers

DND photo by Cpl Yves Genus, CFB Valcartier

Soldiers from the 5th Régiment de Génie de Combat help rebuild pylons with a team from Hydro-Québec near Drommondville, Quebec. They are part of Operation Recuperation, the mission to aid victims of the January 1998 ice storms that ravaged eastern Ontario and western Quebec.

GDA is achieved if situational awareness and/or actionable intelligence is seamlessly integrated across all domains, resulting in synergy across all operational functions. Due to multiple interdependencies and inter-connectivity, GDA supports a spectrum of missions across many agencies and organizations, both civilian and military. Examples may include:

  • modes of transportation within the land domain feed ships within the maritime domain, and vice versa;

  • inter-modal transportation blurs the boundaries between air, land and maritime domains;

  • asymmetric maritime threats expand the wide array of threat vectors; and

  • law enforcement agencies may have the best information, but the military may have the best response capabilities, or vice versa, reinforcing a need for interagency cooperation.

These simple examples are not all-inclusive, but assist in shifting potentially outdated Cold War paradigms24 related to the threat and our responses to various threats. Traditional thinking does little to defeat an asymmetric threat. For instance, an enemy destroyer did not attack the USS Cole, fighter aircraft or cruise missiles did not attack the Pentagon, and the withdrawal from Mogadishu, Somalia, was not the result of a high technology, armoured threat. The boundaries have become blurred between defence, security and law enforcement, resulting in an even greater need for bi-national GDA.

Therefore, BPG assessed the state of maritime surveillance between Canada and the United States as deficient, based upon a lack of bi-national mechanisms, plans, policies and procedures. The realms affected are:

  • International (Canada and US border);

  • Interagency (DND, DoD, Department of Justice, PSEPC, DHS and Federal Emergency Measures Administration);

  • Inter-service (Canadian Forces and US Navy, Air and Land forces and the US Coast Guard); and

  • Inter-modal transportation (land, maritime and air transportation).

Due to a lack of formal shared mechanisms (not ad hoc), such as a fully manned and fully networked maritime information fusing capability between Canadian and US operations centres, the BPG developed a maritime awareness concept that provides information sharing and awareness on vessels of interest (VOI) as a temporary work-around for bi-national maritime awareness. The subsequent proof-of-concept resulted in the positioning of a CF maritime intelligence analyst inside the NORAD-USNORTHCOM Combined Intelligence and Fusion Center (CIFC), who works closely with an American Maritime Intelligence Analyst. Combined information on the VOI is then provided to the Canadian National Defence Command Centre and the US Domestic Warning Center and Current Operations Group.

Research is being conducted by the BPG’s staff and will be conducted between Canadian and US staffs in the areas of intelligence, surveillance and reconnaissance, automated information sharing, intelligence fusion, and development of a shared common operational picture in the maritime domain. Additional gaps in maritime surveillance capabilities and bi-national cooperation, between military and civilian intelligence coordination centres, have been identified in the Great Lakes and St. Lawrence Seaway System (GLSSS). A bi-national team is investigating activities to improve strategic MDA for the GLSSS. MDA issues were also highlighted and discussed at a tabletop exercise that involved a terrorist attack against Detroit and Windsor, in order to outline bi-national responses and requirements. We anticipate that the development of additional coordination issues will naturally evolve as the BPG pursues the bi-national staffing of the BSD and CDP.

Bi-national Exercises and Training

Joint, bi-national training and exercises conducted across all domains would enhance defence of our homelands and could also provide added benefits to Canadian and US forces, should they deploy to an overseas crisis, disaster or emergency. Although NORAD regularly conducts training programs and exercises to respond to threats in the aerospace domain, BPG determined that, excepting NORAD, no major CANUS exercises have occurred in a joint and combined environment for over a decade at the strategic or the Joint Task Force/operational levels in the land or maritime domains. This is a deficiency, since training and exercises are the mechanisms that produce greater interoperability, defined as the ability of systems, units or forces to provide services to and accept services from other systems, units or forces, and to use the services so exchanged to enable them to operate effectively together.

In the near term, as part of our Civil Assistance Plan (CAP) development, the BPG initiated a tabletop exercise (TTE) program to provide scenario-driven discussion and analyses of natural disasters and terrorist incidents. Lessons learned from each TTE on processes, functions and mechanisms are being embedded in both defence and civil support planning. By design, these TTEs were joint and combined, and included military and civilian stakeholders.

Future TTEs will also assist in validating plans prior to submission for bi-national approval, which is compliant with CF OPP and JOPES deliberate planning processes where a plan is developed and then exercised to refinement.25 These TTEs also help establish and then refine appropriate coordination processes and mechanisms among relevant Canadian Departments and US Federal Agencies.

In addition to the TTEs, during the past year, 28 Canadian Forces and OGD/OGA personnel observed USNORTHCOM’s Exercise Unified Defense ‘04, designed to introduce NDHQ J-Staff representatives to USNORTHCOM operational processes and key personnel. This was a good first step toward enhanced cooperation in CANUS training and exercises, but our next step must be actual participation at the strategic and operational levels, geared toward joint and combined mission essential tasks.

In Closing

Alliances are a lot like partnerships, since both require time, attention and work in order to make them successful. Canada and the United States have a unique relationship, as we share common heritage and goals, the world’s longest undefended border, and have integrated and expanding economies. Military personnel from both our nations have served and fought in lockstep from the First World War through our recent operations in Afghanistan.

Soldiers

DND Photo ISd97-069 by Cpl Mike Barley

Soldiers and sailors work hand in hand to deliver thousands of sandbags to threatened homes just south of the Red River Floodway near Winnipeg.

The greatest threat to the CANUS economy, security and relationship could be a terrorist attack that is launched from Canadian territory against the United States, or vice versa. Therefore strengthening CANUS relationships and protocols is essential in this new threat environment.

Enhanced military cooperation is necessary to ensure the defence and security of the North American homeland in view of the asymmetric threats we now face, and to provide fast, efficient, well-trained military assets to assist in civil support missions. Building, sustaining and enhancing relationships between DND and DoD, as well as inter-governmental and interagency relationships with key federal departments and agencies, provinces, states, local organizations and other entities, are critical enablers to improving our conditions for success.

Forces that train in a joint and combined environment increase interoperability. The increases in interoperability between forces in the domestic aerospace, land and maritime domains will also have a synergistic effect upon future coalition operations in the international environment.

Future CANUS military cooperation should be based upon the 46-year success story that is NORAD. As the first step, our nations should continue to improve information sharing among all relevant departments and agencies across the Canadian and US border. The BPG recommends a seamless sharing of information and intelligence between Canada and the United States on defence and security issues.

The BPG’s Interim Report on Enhanced Military Cooperation identified that the new threat paradigm requires new perspectives. Hence, there is a need to move from a ‘need to know’ culture of information protection, to a ‘need to share’ culture between both our sovereign nations. This paradigm shift is not only supported by Canada’s NSP, but also the US Director of Central Intelligence (DCI), who wrote:

“All IC members are hereby directed to ... develop supporting policies, processes, procedures and training needed to achieve the maximum degree of information exchange among IC agencies, with our customers, and with our foreign partners.”26

Although this directive preceded the 9/11 Commission Report, it complies with the intent of their finding, which stated that shifting the traditional ‘need to know’ paradigms to a ‘need to share’ paradigm is critical in order to preclude another surprise attack.27

During the discussions that will lead to the 2006 renewal of the NORAD Agreement, Canada and the US have the opportunity to consider expansion of bi-national cooperation in information sharing, in maritime and land domains, as well as bi-national military assistance to civil authorities in the event of a catastrophic emergency. As our two nations move forward on renewal of this important political agreement, we at the Bi-national Planning Group stand ready to advise and assist.

Both generals wish to express their appreciation to Dr. Biff Baker of the Science Applications International Corporation (SAIC) from BPG for his research and editorial assistance in the preparation of this article.

CMJ Logo

Lieutenant-General Findley, CF, is the Deputy Commander of North American Aerospace Defence Command and the Head of the Bi-national Planning Group. Lieutenant General Inge, US Army, is the Deputy Commander of United States Northern Command and Deputy Head of the Bi-national Planning Group.

Notes

  1. Throughout this document, CANUS is merely an acronym, which means “Canada and the United States”.
  2. The Honorable Rob Wright, National Security Advisor to the Prime Minister of Canada and Associate Secretary to the Cabinet, at the Fletcher Conference, 28 October 2004.
  3. U.S. Strategic Planning Guidance 2004, p. 3.
  4. Securing an Open Society: Canada’s National Security Policy (NSP) and the National Security Strategy (NSS) of the United States of America.
  5. Securing an Open Society: Canada’s National Security Policy (NSP).
  6. President George W. Bush, Summit of the Americas, 13 January 2004.
  7. NSS of the United States of America, p. 25.
  8. Joint statement by Canada and the United States on common security and common prosperity: A New Partnership in North America, 30 November 2004, Ottawa, Ontario, Canada.
  9. The Honorable Paul McHale, 28 October 2004.
  10. The entire Diplomatic Note is contained in Appendix I of the BPG’s Interim Report on Enhanced Military Cooperation, dated 13 October 2004, and located at <www.northcom.mil/>.
  11. The entire Terms of Reference (TOR) is contained in Appendix II of the BPG’s Interim Report on Enhanced Military Cooperation, dated 13 October 2004, and located at <www.northcom.mil/>.
  12. Terms of Reference (TOR for the Bi-national Planning Group (BPG), para. 5. a.
  13. Ibid., para. 5. b.
  14. Ibid., para. 5. c.
  15. Ibid., para. 5. d.
  16. Ibid., para. 5. e.
  17. Ibid., para. 5. g.
  18. See the BPG Library at <www.northcom.mil/>.
  19. US system is modified as bi-national system from the JFSC Pub 1, The Joint Staff Officer’s Guide, pp. 4-8.
  20. Intent of the BSD was taken from the MCC Information Book, para. 13, p.19.
  21. See Joint Forces Staff College Publication 1 (JFSC Pub 1), pp. 2-11. The NSS is signed by the President and contains strategic guidance concerning the continued security and prosperity of the United States; the NSP serves a similar role within the Canadian system.
  22. The MDA definition was articulated at the MDA Working Group, May 2004.
  23. BPG’s Interim Report on Enhanced Military Cooperation, dated 13 October 2004, p. 36, at <www.northcom.mil/>.
  24. The Cold War paradigm focused upon: 1) bipolar structure; 2) Communist versus Capitalist ideologies; 3) conflict primarily between state actors; and 4) symmetric threats where the airplane was the best weapon against an airplane, a tank was best against a tank, and a ship against a ship, and so on, thus reinforcing symmetric thinking and rendering the US vulnerable to an asymmetric attack on 11 September 2001.
  25. The Joint Staff Officer’s Guide, JFSC Publication 1, p. B-3, para. g.
  26. DCI Directive 8/1, dated 4 June 2004.
  27. 9-11 Commission Report, p. 390.