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Wednesday, February 14, 2007
Posted by: Hugh Hewitt at 11:57 AM

NOTE: I have added at the bottom of this post the text of two letters I requested from Professor Feith from his lawyer to the DOD’s IG on the subject of “inappropriate” behavior on the part of Feith and his staff, as well as the text of the current Undersecretary of Defense Erik Edelman’s response to the IG Report.

This is a long post, as I am going to try and collect in one place the key documents and links a reader will need to understand that the another in the many attempts to rewrite history to serve an antiwar political agenda.

The key question: In the late '90s and early years of this decade, did the CIA do a good job in predicting 9/11 or assessing Saddam's WMD? Those two numbers and three letters provide the context for the sham "controversy" surrounding former Undersecretary Douglas Feith. Did the CIA see 9/11 coming? Did the agency produce any reports asserting boldly that Saddam did not have the WMD that everyone thought he did?

Was the CIA, in 2002, an agency to be trusted to get the big ones right?

Of course not. The professionals of the agency tried, but they failed. After 9/11 the professionals at the DoD decided to look hard at the intelligence product coming out of the CIA concerning al Qaeda and Saddam. Now partisans are attempting to argue that DoD shouldn't do such a thing --a conclusion that would be hilarious if it wasn't so dangerous.

In an example of how the Administration and its past members ought to be conducting the war against the war against the war, former Undersecretary of Defense Douglas Feith has an op-ed in today's Washington Post that eviscerates Carl Levin and the media coverage of the report by the Pentagon's Inspector General which caused a flurry of misleading headlines last week. The Wall Street Journal has already rightly characterized Levin as having gone Ahab over Feith, but this isn't a tale of one senator's scurrilous behavior. It is a much larger drama that goes to how badly broken our intelligence gathering was and probably remains.

After our interview yesterday, (transcript here and key excerpts here) I began to assemble the relevant documents which fully support the assertion that Feith's office had been fully exonerated, and that Levin's grandstanding was itself cherry-picking of a report he had demanded but which had not only not convicted Feith and staff of illegal, unauthorized or misleading conduct, but which opens the door again to the central problem of the CIA Bill Clinton left behind --a thoroughly politicized and broken organization that has spent the past six years attempting to divert attention from the massive intelligence failure that led to 9/11 and the second intelligence failure that assumed large quantities of WMD in Iraq prior to the invasion. Those documents include Feith's statement from Friday, the transcript of the Senate hearing from that day, and also the report of the Republican Policy Committee, chaired by Arizona's Jon Kyl, which concluded:

The allegations of unlawful, improper and inappropriate activities by the Office of theUnder Secretary of Defense for Policy with regard to Iraq pre-war intelligence reflect misunderstandings about the facts and impractical ideas about how the U.S. government works. These allegations have been looked at and dismissed by the Senate Select Committee on Intelligence. It is irresponsible for critics of the administration in the U.S. Senate and elsewhere to continue to put these allegations forward when they know, or should know, that there is no evidence to support them.

Here is a key excerpt from the hearing, a summary statement by Senator Inhofe:

Inhofe: First of all, you can read the same report and come up with different conclusions, which is quite obvious and will be obvious. And I think that we, of course, want to hear from Mr. Gimble on the report so we can come to our own conclusions.

I don't think in any way that his report could be interpreted as a devastating condemnation, as you point out, Mr. Chairman.

You know, I've talked to the chairman of the Intelligence Committee, Pat Roberts, on numerous occasions about this. And they've gone over it and over it and over it; had the Intelligence Committee, which is bipartisan; the bipartisan WMD committee -- Silberman and our former colleague Chuck Robb -- separately examine these matters in detail. Each concluded unanimously that no intelligence analysts were pressured.

The Intelligence Committee also found that there was no basis for any allegations that have been made against the undersecretary. Roberts wrote to the Department of Defense inspector general -- now, he was the first one to make this request, and he did so for this reason -- this is his quote now: "The committee is concerned about persistent and, to date, unsubstantiated allegations that there was something unlawful or improper about the activities of the Office of Special Plans with the Office of the Undersecretary. I have not discovered any credible evidence or unlawful or improper activity. And yet the allegations persist."

In attempt to stop these allegations once and for all, he had made the request to the inspector general's office.

I would have to say, also, Mr. Chairman, that these matters have been scrutinized at least three times in the last three years by bipartisan, nonpartisan groups. The Intelligence Committee unanimously reported that it found that this process, the policy- makers' probing questions, actually improved the CIA's process. In other words, what they were doing in getting into this thing and bringing these issues up caused the intelligence community to go back and relook and to reexamine and to do a better job than they were going to do otherwise.

Some intelligence analysts even told the committee that policy- makers' questions had -- and I'm quoting now -- "questions had forced them to go back and review the intelligence reporting," and that during this exercise they came across information that they had overlooked in the initial readings. In other words, they actually provided a service by bringing these things up.

As I mentioned to you, Mr. Chairman, I'll be leaving in 20 minutes to catch a plane, so I won't be bothering you too long here.

Thank you very much.

And here is Feith's statement from Friday:

It is good but not surprising that the Inspector General (“IG”) found that the Pentagon Policy office’s activities were all legal and authorized and that Policy officials did not mislead Congress.

The Policy office has been smeared for years by allegations that its pre-Iraq-War work was somehow “unlawful” or “unauthorized” and that some information it gave to congressional committees was deceptive or misleading. The office’s accusers always couched the charges in vague language, making them difficult to refute with precision. The charges have been repeated persistently despite the lack of any substantiation. The IG report has now thoroughly repudiated the smears.

In faulting Pentagon policy officials for “inappropriately” criticizing the CIA’s pre-Iraq-war intelligence, however, the IG report takes an absurd position. The report says that written criticism of the CIA’s work is an “intelligence activity” inappropriate for policy officials. But professional criticism of intelligence by policy officials is a good thing. The Pentagon briefing at the heart of this matter was a good thing and our government is better off when policy officials challenge speculative intelligence. Both the Senate Intelligence Committee and the Silberman-Robb WMD Commission said we need more, not less, criticism of intelligence work by policy officials.

The Silberman-Robb WMD Commission said:

While policymakers must be prepared to credit intelligence that doesn’t fit their preferences, no important intelligence assessment should be accepted without sharp questioning that forces the community to explain exactly how it came to that assessment and what alternatives might also be true. This is not “politicization;” it is a necessary part of the intelligence process. [March 31, 2005 Transmittal Letter]

The Pentagon critics of the CIA created a briefing specifically for the purpose of criticizing poor intelligence work. The IG report attacks the briefing’s quality not on the basis of an examination of the underlying intelligence but because the briefing varied from the consensus of the intelligence community. It, of course, varied from that consensus – it was a criticism of that consensus. That is why it was written. It makes no sense to say it was unreliable for that reason.

The briefing activity was the very same work that the Senate Intelligence Committee praised in its July 2004 report, which was endorsed by all the Democrats as well as all the Republicans on the committee. That report concluded that the Policy officials involved acted professionally, “played by [intelligence community] rules” and asked questions that “actually improved the [CIA’s] products.”

It is bizarre for the Inspector General to disapprove of policy officials’ doing work that they were directed to do by the Secretary or Deputy Secretary of Defense, given that those tasks were lawful and authorized and the Inspector General found nothing at all wrong with the Secretary and Deputy Secretary directing that the work be done.

If the Inspector General’s opinions about appropriate criticism were followed, they would discourage policy officials from asking tough questions about the quality of CIA work. Pentagon policy officials asked good, honest, critical questions, challenging the CIA, whose work (as everyone now knows) was by no means flawless and above challenge. That the CIA did not agree with the criticism from the Pentagon does not mean that the criticism was unreliable or inappropriate and it is illogical for the IG to say it does.

Clearly, the Inspector General’s office was willing to challenge the Policy office and even stretch some points to be able to criticize it. So it is all the more impressive that the Inspector General’s report so thoroughly and categorically rejects the persistent smears of the Policy office regarding unlawful or deceptive activity.

More to follow as I find it, but anyone who thinks the DoD was wrong to look long and hard at CIA conclusions or that it was inappropriate for the DoD to analyze the CIA's findings isn't serious about the national security.

UPDATE:

I requested and received two letters which Douglas Feith's lawyer provided the DoD IG on the absurd finding of "inappropriate" behavior. As anyone who has ever worked with an IG realizes, this is an accordian term with no legal standard attached to it, and thus the worst sort of judgment an IG can render --a necessarily political one.

Letter #1: Dated: August 2, 2006, Patton Boggs letterhead:

Office of the Inspector General, Department of DefenseATTN: Lieutenant Colonel Charles E . Edge

Office of the Deputy Inspector General for Intelligence

400 Army Navy Drive, Room 703

Arlington, VA 22202-4704

Re: Follow-up to Interview of The Honorable Douglas J. Feith

Dear Colonel Edge:

During the interview of Mr. Feith on July 20,2006, you asked about a meeting he had in

his home with a then-civilian employee of the Office of the Under Secretary of Defense for

Policy (OUSDP) in 2004. Mr. Feith recounted his recollection of the meeting for you and your

colleagues and stated that Mr. Michael Mobbs, another OUSDP civilian employee, was the third

person present at the meeting. Mr. Mobbs, who still works at OUSDP, drafted a memorandum

of the conversation at that 2004 meeting. Mr. Feith approved and initialed the memo on May 13,

2004, and sent it to the Principal Deputy General Counsel, Mr. Dan Dell'Orto. After you

requested a copy at our July 20 interview, Mr. Dell'Orto provided us one. We enclose a copy foryour review.

This memorandum of conversation was prepared long before the DODIG began its

review of the OUSDP. It reflects Mr. Feith's attitude about the role of the policy makers versus

the role of intelligence officials while he was serving as Under Secretary. The memorandum is ayour review.

The memorandum of conversation was prepared long before the DODIG began its

review of the OUSDP. It reflects Mr. Feith's attitude about the role of the policy makers versus

the role of intelligence officials while he was serving as Under Secretary. The memorandum is a

record of Mr. Feith's decisive action to avoid even any perception that his policy staff was

engaging in activity that should be done only by the intelligence community. His orders to the

employee were emphatic and unequivocal - no policy employee was to do anything, "no matter

how well-intentioned" that could be interpreted (or that might be expected to be misinterpreted)

as intelligence activity.

The memorandum highlights a central issue in your review, that is, the distinction

between policymaking and intelligence activity. It shows that Mr. Feith was concerned about the

distinction and wanted to ensure that his subordinates respected it.

You informed us that, at this point in your review, you have found no instances of illegal

or unauthorized activity. You said the open question was whether any activity had been

inappropriate. You commented on the absence of a relevant, defined standard for "appropriate"

activity. We suggest you consider the following as a standard for deciding whether an activity you

are reviewing was appropriate.

Where there has been no activity violating the laws, regulations or DoD directives that

define and authorize the work of the OUSDP, then appropriateness should turn on whether the

activity in question was transparent or known to Mr. Feith's immediate superiors in the chain of

command and maybe also to his counterparts in the interagency national security decision-making

apparatus.

By "transparent" we mean visible to and understood by Mr. Feith's superiors. Even if an

activity is legal and authorized, a superior in the chain of command clearly has broad discretion to

limit or terminate it as inappropriate, if that superior so chooses. If a properly informed superior,

regarding an otherwise lawful and authorized activity, declines to limit or terminate it, the activity

has to be deemed appropriate.

When this "lawful - authorized - transparent" standard is applied to the activity you are

reviewing, we believe the conclusion will be that the activity was appropriate. Consider, for

example, the so-called Shelton briefing. After the briefing was given to Mr. Feith, he directed

that it be given to the Deputy Secretary and the Secretary of Defense. The Secretary then

directed that it be given to the Director of Central Intelligence who received it with a number of

senior staff present. The briefing was then openly discussed in a Deputies Committee meeting,

including by the Deputy Director of Central Intelligence. That discussion led to Stephen

Hadley's request, as Deputy National Security Advisor, to receive the briefing. Throughout the

whole process, the existence of the briefing and its contents were transparent to Mr. Feith's chain

of command and to key interagency colleagues. Neither Mr. Feith's superiors in the Department

of Defense nor those interagency colleagues expressed the view that it was inappropriate. Under

such circumstances, we believe the only reasonable conclusion is that the activity was appropriate.

It was lawful, authorized and transparent.

If you would like to discuss any of these issues further or we can be of further assistance,

please do not hesitate to contact us.

Sincerely,

Michael J. Nardotti, Jr.

Major General, US Army, Retired

Letter #2: Dated September 28, 2006, Patton Boggs letterhead:

Office of the Inspector General, Department of Defense

A'TTN: Lieutenant Colonel Charles E. Edge

Office of the Deputy Inspector General for Intehgence

400 Army Navy Drive, Room 703

Arlington, VA 22202-4704

Re: The Honorable Douglas J. Feith

Dear Colonel Edge:

Thank you very much for taking the time to talk on Tuesday. As always, we appreciate your

candor and your willingness to keep us apprised, to the extent that you are able, of the status of

the review concerning Mr. Feith and his former office.

We also appreciate knowing that with your interviews now completed you have found no

instances of illegal or unauthorized activity. Because the third issue raised in Senator Roberts'

letter - whether any activity was "inappropriate" - remains a challenge due to the lack of a defined

standard, we offer additional thoughts for your consideration. These thoughts supplement our

August 2,2006 letter to you.

We said previously that where there was no activity violating the laws, regulations, or DoD

directives that define and authorize the work of the OUSDP, the appropriateness should turn on

whether the activity in question was tmsparent or known to Mr. Feith's immediate superiors in

the chain of command and perhaps also to his counterparts in the interagency national security

decision-making apparatus. We also said that, if a properly informed superior in the chain of

command allows a lawful and authorized activity to go forward, that activity has to be deemed

appropriate. The superior, after all, could limit or terminate it as inappropriate. Applying this

"lawful - authorized - transparent" standard to the activity you are reviewing then, we believe the

activity was clearly appropriate.

In highlighting the "transparency" element, we are not suggesting that the superior's visibility

over the activities - by itself - determines the issue. Also critically important is the superior's

authority and responsibility to act if faced with inappropriate activity. The superior could act.

There should be a presumption that the superior would act if the activity were inappropriate.

Moreover, in the particular circumstances of this case, we believe it is important to point out that

Mr. Feith's superiors did not merely have visibility of the activities in which his staff was

engaging. His superiors were engaged in those activities. Mr. Feith properly notified them of his

staff's work and arranged a briefing of the Deputy Secretary and the Secretary of Defense. Once

that took place, the Secretary directed the briefing be given to the QA Director, and it was

through the Deputy Secretary's intervention that the briefing eventually was given to the NSC

Deputy. Mr. Feith was acting as a member of a team here, not as an independent figure. The

Secretary and Deputy Secretary had ample discretion to act as they did, and in doing so they

reflected the belief that their activity and Mr. Feith's were appropriate.

We would be happy to discuss these thoughts in more detail with you and your team or the IG

General Counsel, whenever convenient. Please let us know what we may do to help.

Sincerely,

Michael J. Nardotti, Jr.

Major General, U.S. Army, Retired

UPDATE: Here is the response ot the IG Report from the current Undersecretary of Defense Edelman's office. It is 53 pages long, but useful in its damning detail:

COMMENTS BY THE OFFICE OF THE UNDER SECRETARY OF DEFENSE ON ADRAFT OF A PROPOSED REPORT BY THE DOD OFFICE OF INSPECTOR GENERAL

PROJECT NO. D2006DINTOl-0077.000

REVIEW OF PRE-IRAQI WAR ACTIVITIES OF THE OFFICE OFTHE UNDER SECRETARY OF DEFENSE FOR POLICY (U)

January 16,2007

OUSD(P) COMMENTS ON DRAFT OF A PROPOSED REPORT BY THE DOD OFFICE OF INSPECTOR GENERALREVIEW OF PRE-IRAQI WAR ACTIVITIES OF THE OFFICE OF THE UNDER SECRETARY OF DEFENSE FOR POLICY (U) PROJECT NO. D2006DINT01-0077.000

January 16,2007

TABLE OF CONTENTS

I. SUMMARY OF KEY ERRORS IN THE DRAFT REPORT (U) ................................. 4

11. THE POLITICAL BACKGROUND OF THIS MATTER (U) .................................... 7

111. OUSD(P) SUPPORT TO THE OIG REVIEW (U) ................................................... 11

IV. FACTS (U) ................................................................................................................. 11

A. THREE SEPARATE ACTIVITIES RELATING TO THE WORK UNDER REVIEW (U) . . . . . . . . 12

1. The PCTEG (U) ................................................................................................... 13

2. The DIA Analyst Detailed to the Policy Support Office (U) ............................ ..... 16

3. The Deputy Secretary's Tasking to Brief the Secretary of Defense (U) ............... 18

B. DRAFT BRIEFING TO THE SECRETARY OF DEFENSE (U) ........................................... 22

C. THE SECRETARY OF DEFENSE'S DIRECTION TO BRIEF DCI, DRAFT BRIEFING TO DCI,

CIA MEETING (U) .......................................................................................................... 25

D. DEPUTY NATIONAL SECURITY ADVISOR'S REQUEST, DSD's DIRECTION, DRAFT

BRIEFING TO DEPUTY NATIONAL SECURITY ADVISOR (U) ........................................ 27

E. DCI ' s CONGRESSIONAL STATEMENTS ON IRAQ AND AL-QAID A (U) . . . . . . . . . . . . . . . . . . . . . . . 2 8

V. DISCUSSION (U) ....................................................................................................... 3 1

A. WHY ARE LAWFUL AND AUTHORIZED ACTIVITIES NEVERTHELESS CALLED

"INAPPROPRIATE"? (U) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1

B. DIA'S DI POLICY NOS. 004 AND 005 DO NOT APPLY TO IVON-IC OFFICES DIRECTED

BY SENIOR DoD LEADERS TO CRITIQUE INTELLIGENCE COMMUNITY WORK (U) . . . . . . . . 3 3

1. The Internal DIA Policies Do Not Apply to DIA Members While Detailed to

Policy Positions Outside DIA 's Chain of Command (U) ........................................ 34

2. The Internal DIA Policies Contain No Procedure for an IC Customer to Obtain

an Alternative IC Judgment, Which in any Case is not What the DSD Sought Here

(U) . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

3. The Internal DIA Policies Were Not Coordinated or Published as Would Have

Been Required ifIntended to Apply Outside DIA (U) ............................................... 35

C. "INTELLIGENCE ACTIVITIES" CONSTITUTE A PROCESS USING ALL KEY ELEMENTS

OF INTELLIGENCE WORK BY INTELLIGENCE AGENCIES (U). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5

D . ALTERNATIVE OR CRITICAL ASSESSMENTS OF IC INFORMATION AND IC JUDGMENTS

BY NON-IC OFFICES ARE NOT "INTELLIGENCE ACTIVITIES" (U) ................................. 37

E . OUSD(P) DID NOT PRODUCE OR DISSEMINATE "INTELLIGENCE ASSESSMENTS" OR

"INTELLIGENCE ANALYSIS" (U) .................................................................................... 38

F . THE RELEVANT ORDERS AND DIRECTIVES DESCRIBE INTELLIGENCE ROLES AND

ACTIVITIES. THEY DO NOT PROSCRIBE POLICY ACTIVITIES (U) ................................... 40

VI . OUSD(P) NONCONCURRENCE (U) ...................................................................... 43

..................................................... . A WITH THE FINDINGS OF THE DRAFT REPORT (U) 43

................................... . B WITH THE COMMENDATIONS OF THE DRAFT REPORT (U) 44

................................................................................................... . VII CONCLUSION (U) 45

. ........................................................... APPEIVDIX A: DI POLICY NOS 004 AND 005 47

APPENDIX B: COMMENTS ON OIG'S ANSWERS TO SENATOR LEVIN ............ 50

OUSD(P) COMMENTS ON

DRAFT OF A PROPOSED REPORT

BY THE DOD OFFICE OF INSPECTOR GENERAL

REVIEW OF PRE-IRAQI WAR ACTIVITIES OF THE OFFICE OF THE

UNDER SECRETARY OF DEFENSE FOR POLICY (U)

PROJECT NO. D2006DINT01-0077.000

January 16,2007

The Committee believes that IC analysts should expect difficult and repeated questions regarding

threat information. . . .The Committee found that this process - the policymakers probing questions -

actually improved the [CIA 's]products. ... While analysts cannot dismiss a threat because at first

glance it seems unreasonable or it cannot be corroborated by other credible reporting, policymakers

have the ultimate responsibility for making decisions based on this same fragmentary, inconclusive

reporting.'

(U) The Office of the Under Secretary of Defense for Policy (OUSD(P)) offers the

following comments on a December 20,2006 Draft of a Proposed Report (the "Draft

Report") by the Department of Defense Office of Inspector General ("OIG") in Project

No. D2006DINTO 1-0077.000, "Review of Pre-Iraqi War Activities of the Office of the

Under Secretary of Defense for Policy (U)" (the "Project").

(U) Throughout these comments we observe that the work on which this Project

concentrates, and in particular the specific activities that the Draft Report characterizes as

"inappropriate," were authorized and directed to be done by the Deputy Secretary or the

Secretary of Defense. For the purpose of these comments, references to "work" or

"activities" "authorized" and "directed" by the Secretary, the Deputy Secretary, "the most

senior leaders" of DoD, or "senior DoD leaders" specifically mean the following:

(U) The Deputy Secretary of Defense ("Deputy" or "DSD") directed his Special

Assistant in his front office and two staff members in OUSD(P) to take a fresh, critical

look at Intelligence Community ("IC") reporting on contacts between Iraq and al-Qaida.

In working on the Deputy's tasking, one of the OUSD(P) staffers prepared an internal

memo containing two commentary paragraphs followed by a list summarizing IC reports

on contacts between Iraq and al-Qaida. The staffers wrote up the critique requested by

DSD in the form of a draft briefing that discussed IC reports on Iraq-al-Qaida contacts

and how these reported contacts might be viewed absent an a priori assumption that

secular Baathists and Islamic extremists would never cooperate. The Deputy Secretary

1 (U) Report of the Select Committee on Intelligence on the US. Intelligence Community's Prewar

Intelligence Assessments on Iraq (U) (9 July 2004), pp. 34, 35 (unanimous report, unclassified version)

("SSCI Report").

directed that the draft briefing be given to the Secretary of Defense. After receiving it,

the Secretary directed that it be shared with the DCI. The Deputy Secretary's office also

d.irected that the draft briefing be given to the Deputy National Security Advisor when the

latter requested it.

I. SUMMARY OF KEY ERRORS IN THE DRAFT REPORT (U)

(U) The title of the Draft Report is inaccurate. The work on which the Draft Report

focuses was not "OUSD(P)"'activity. It was in fact a response to tasking by the

Deputy Secretary of Defense, who in July 2002 directed his Special Assistant in his

front office and two staff members in OUSD(P) to critique IC reporting on contacts

between Iraq and al-Qaida. The result was a draft briefing on how those contacts

might be viewed if one did not assume a priori that secular Baathists and Islamic

extremists would never cooperate. The Deputy Secretary directed that the draft

briefing be given the Secretary of Defense. After receiving it, the Secretary directed

that it be shared with the DCI. When the Deputy National Security Advisor requested

the draft briefing, the Deputy Secretary's office directed that it be given to him.

(U) The work reviewed was not an "OUSD(P)" activity, assessment, view, position or

initiative, despite the Draft Report's repeated assertions to the contrary. The Under

Secretary of Defense for Policy (USDP) never approved, adopted or advocated the

draft briefing or any of the work leading to it as an "OUSD(P)" view or assessment.

Each version of the briefing was marked "draft" or "draft working papers" and was

never presented as anything other than that.

(U) The Draft Report correctly finds that these activities were lawful and authorized.

It correctly states (page 34) that "the Secretary [of Defense] owns the DoD Directives

governing (among others) Intelligence and Policy, and as long as Executive Orders or

other legal statutes are not violated, he has the latitude to interchange roles and

responsibilities." But in contradiction of these same findings, the Draft Report

incorrectly calls the activities "inappropriate," because they supposedly amounted to

"dissemination" to senior decision-makers of "alternative intelligence assessments"

"inconsistent" with the "consensus" of the IC.

(U) If the OIG believes that it was inappropriate for the Deputy Secretary of Defense

to have non-IC OSD staff members critique IC work on a significant subject of

national security, inappropriate for the Secretary of Defense to share the OSD work

with the DCI, and inappropriate for the Deputy Secretary to share the work with the

Deputy National Security Advisor when requested by the latter, the OIG should say so

directly instead of finding fault with subordinate OSD offices and staff members who

did as the Secretary or Deputy Secretary instructed.

(U) The entire argument in the Draft Report rests on the definition of "Intelligence

Activities" and the meaning of "intelligence assessments." The Report's

interpretation of the definition of "Intelligence Activities" found in the relevant DoD

directive is wrong. By its definition, that term on its face applies only to intelligence

agencies, not to policy offices.

(U) Because OUSD(P) routinely and properly acquires, assesses and distributes

"information relating to the capabilities, intentions, and activities of foreign powers,"2

stretching the definition of "Intelligence Activities" to include policy offices would

lead to the absurd result of mischaracterizing most work done in OUSD(P) as

"Intelligence Activities."

(U) The Report does not define the term "intelligence assessments" but erroneously

asserts that a critique by non-IC staffers of IC assessments was itself an

"inappropriate" "intelligence assessment." There are no facts in the Draft Report, or

otherwise, supporting the assertion that this work was presented as "intelligence

assessments.''

(U) There are likewise no facts suggesting that the "senior decision-makers" who

were briefed on this work, specifically, the Secretary of Defense, the Deputy

Secretary of Defense, the DCI, the Deputy National Security Advisor, and the Vice

President's Chief of Staff, mistook this work to be "intelligence assessments."

(U) The Report fails to make clear that the Office of Special Plans (OSP), the Policy

Counter Terrorism Evaluation Group (PCTEG), and the Policy Support Office did not

perform and had no responsibility for any of the work reviewed in this Project. This

failure is especially egregious in light of press reports and political criticism that

continue to assert the contrary.

(U) The Draft Report labels the work products at issue as "inappropriate" (page 4)

because they allegedly "did not clearly show the variance with the consensus of the

Intelligence Community" and "were, in some cases, shown as intelligence products."

But the senior decision-makers briefed on this work (one of whom was the DCI

himself) did not need to be told that it varied in some respects from IC analysis; that

was inescapably obvious. There are no facts to suggest that any of them drew any

conclusions or made any decisions whatsoever solely on the basis of .the draft

briefing, without taking IC views into account. There are no facts supporting the

claim that some work products "were, in some cases, shown as intelligence products."

2 (U) Part of the definition of "foreign intelligence," which in turn is part of the definition of "Intelligence

Activities." See DoD Directive No. 5240.1, DoD Intelligence Activities," 25 April 1988, Sections 3.1

and 3.2.

(U) OUSD(P) did not impede or undercut any responsibilities of the Intelligence

Community, contrary to suggestions in the Draft Report. The IC was fully aware of

the work under review and commented on it several times, as the Draft Report itself

reveals. Further, the DCI was personally briefed on the work at the Secretary of

Defense's direction.

(U) OUSD(P) did not bypass any applicable DIA procedures, contrary to assertions in

the Draft Report. The DIA's DI Policy Nos. 004 and 005, cited by the Draft Report,

are internal DIA guidelines that only apply to DIA analysts, working as such, who

wish to produce alternative analyses or alternative judgments within DIA's chain of

command. These guidelines are irrelevant to customer offices of the IC - the

consumers of intelligence -- that wish to suggest an alternative way of viewing

information and analyses already provided by the IC. Nor do these guidelines provide

any mechanism for DIA customers to request an alternative judgment by the IC,

which in any case is manifestly not what the Deputy Secretary desired when he

directed the work under review to be done.

(U) While some of the work reviewed in this Project did characterize the Iraq-al-

Qaida relationship as "cooperative," that characterization did not contradict IC

judgments on the subject at the time. To the contrary, the reference in .the draft

briefing to a "cooperative" Iraq-al-Qaida relationship was consistent with the DCI's

own statements to Congress in 2002 and 2003. He said then that "we have solid

reporting of senior level contacts between Iraq and al-Qaida going back a decade,"

"credible information indicates that Iraq and al-Qaida have discussed safe haven and

reciprocal non-aggression," "we have solid evidence of the presence in Iraq of al-

Qaida members," "the reporting also stated that Iraq has provided training to al-Qaida

members in the areas of poisons and gases and making conventional bombs," etc.

The Draft Report ignores these DCI statements.

(U) The Draft Report erroneously faults OUSD(P) for failin to provide "the most f accurate analysis of intelligence" to senior decision-makers. That responsibility rests

with the IC, not OUSD(P). More importantly, senior decision-makers already had the

IC's reports and assessments on Iraq and al-Qaida and thus already had "the most

accurate analysis of intelligence" -- if one accepts, as the Draft Report seems to do,

that .the IC's assessments are the "most acc~rate."~

3 (U) This criticism is symptomatic of the peculiar and sometimes contradictory logic of the Draft Report,

for the Draft Report also holds that OUSD(P) should not provide any intelligence analyses at all.

4 (U) The Draft Report purports to make judgments about the nature of the Iraq-al-Qaida relationship, but

these judgments appear to be based on certain CIA and DIA analytical papers -- not on any

contemporaneous NIE or other authoritative consensus by the IC as a whole -- and without reference to

the DCI's own statements on the subject. There is no evidence in the Draft Report that the OIG

(U) The Draft Report recommends (page 14) that, if OUSD(P) disagrees with an IC

consensus, OUSD(P) should "clearly articulate in policy products the Intelligence

Community consensus and the basis for disagreement or variance from the

Intelligence Community consensus." Such a requirement would inappropriately

constrain policy work by requiring policy offices to vet every policy recommendation

or analysis with the IC in order to determine whether or not it disagreed or varied with

an IC "consensus." It would also burden policy offices with a requirement to

articulate the IC "consensus" when the IC itself should do so.

(U) Bipartisan reports and studies by various commissions and congressional

committees since the 911 1 attacks have stressed the need for vigorous debate, hard

questions and alternative thinking of the sort that motivated the work reviewed in this

Project. The conclusions and recommendation in the Draft Report reflect a disturbing

departure from the lessons of all these reports and studies. By faulting a critical

assessment in OSD of IC work on contacts between Iraq and al-Qaida, the Draft

Report would inhibit the vigorous debate and hard questioning that most observers

recognize as essential. The Draft Report's conclusions, if sustained, would have a

dampening effect on future initiatives challenging intelligence assessments. The facts

do not justify such conclusions.

11. THE POLITICAL BACKGROUND OF THIS MATTER (U)

(U) The activities reviewed in this Project, unfortunately, have been the object of

bitter political debate and inaccurate press reporting for over three years. Given the

partisan nature of the matter, it was particularly important that the OIG's independent

review adhere to the strictest standards of factual accuracy, rigorous analysis, and clarity

of expression. Unfortunately, the Draft Report does not meet those standards.

(U) Apart from numerous factual inaccuracies, omissions and mischaracterizations

identified throughout these comments, the Draft Report suffers from a basic analytical

flaw in attempting to paint the work under review as "inappropriate" even though no laws

were broken, no DoD directives were violated, and no applicable policies were

disregarded. The Draft Report concedes that the activities reviewed were lawful. It

concedes that the activities were authorized - indeed requested - by the Deputy Secretary

and Secretary of Defense. In perhaps its most trenchant observation, the Draft Report

correctly states (page 34) that "the Secretary owns the DoD Directives governing (among

others) Intelligence and Policy, and as long as Executive Orders or other legal statutes

are not violated, he has the latitude to interchange roles and responsibilities" (emphasis

added).

undertook any rigorous, independent review of the underlying intelligence on the issue of contacts

between Iraq and al-Qaida.

(U) That observation goes to the heart of the present matter. It shows that the

activities in question were clearly appropriate. No statutes or executive orders were

violated. The Secretary, and by extension the Deputy, unequivocally had the latitude to

obtain an alternative, critical assessment of IC work on Iraq and al-Qaida from non-IC

OSD staff members rather than from the DIA or the Assistant Secretary of Defense for

C31, without vetting such critique through any Intelligence Community process. The

Secretary had the latitude to direct the authors of such critique to share it with the DCI.

The Deputy Secretary had the latitude to direct the authors of such critique to share it

with the Vice President's Chief of Staff and the Deputy National Security Advisor when

the latter so requested. This should have put an end to any question of appropriateness.

(U) The OIG is empowered and competent to determine whether the activities

were lawful and authorized. But we question whether it is "appropriate" for the OIG to

venture into the realm of opinion about whether the activities were appropriate, in the

absence of any applicable standards, regulations, directives, etc. This is especially true

where, as here, the OIG has found the activities in question were lawful and authorized,

and has conceded that the Secretary and Deputy have the "latitude to interchange roles

and responsibilities" in overseeing DoD.

(U) We respectfully observe that the OIG's opinion on the subjective question of

"appropriateness" in these circumstances is not entitled to any particular deference. The

OIG does not have special expertise on this issue, which is fraught with policy and

political dimensions. Given the politically charged atmosphere infecting this entire

matter, it is especially objectionable for the OIG to obscure and minimize the fact that the

Secretary and Deputy Secretary directed the activities in question be done, to

mischaracterize the work as "OUSD(P)" activities, and to find something "inappropriate"

in the fact that subordinate offices and staffers did as the Secretary and Deputy directed.

(U) Moreover, the Draft Report employs a demonstrably incorrect reading of

"Intelligence Activities" to portray the work reviewed as "alternative intelligence

assessments," "Intelligence Production" and the like, when in fact it was not. This

mischaracterization is particularly egregious in light of the persistently false press reports

and political accusations claiming that the Deputy Secretary, or OUSD(P), or others in

the Defense Department distorted intelligence in order to argue that Iraq had a direct role

in the 911 1 attacks, or that Iraq and al-Qaida had a stronger relationship than shown by

facts known at the time, in order to propel the United States to war on false pretenses.

(U) Before the OIG ever took up this matter, it had been the subject of an

exhaustive investigation that the Senate Select Committee on Intelligence (SSCI) began

in July 2003, as well as a "minority inquiry" begun by Senator Carl Levin in June 2003.

(U) In July 2004, the Committee issued a unanimous report on "Phase I" of its

investigation. That report concluded inter alia that policymakers at no time pressured the

IC to change its conclusions on Iraq's links to terrorism, and that the work of OSD

staffers reviewed here did not result in any changes to the analytical judgments in IC

work on Iraqi support for terrorism.' The Committee deferred to a second phase of its

investigation an evaluation of whether the work products now under OIG review were

"objective, reasonable, and acc~rate."~ Because of divisions along partisan lines within

the SSCI, its members have not to date been able to agree on what conclusions to reach in

its "Phase 11" report.

(U) SSCI Chairman Pat Roberts referred this matter to OIG only because these

partisan divisions prevented the SSCI from reaching agreement on what to say about the

activities reviewed in this Project. By the time he made the referral to OIG, the issue had

been transformed from whether the work in question was "objective, reasonable and

accurate" to whether it was "unauthorized, unlawful or inappropriate" -- even though the

SSCI had uncovered no information to support such a characterization.

(U) In his September 9, 2005 letter requesting an independent review by OIG,

Chairman Roberts wrote that "the Committee is concerned about persistent and, to date,

unsubstantiated allegations that there was something unlawful or improper about the

activities of the Office of Special Plans within the office of the Under Secretary of

Defense for Policy during the period prior to the initiation of Operation Iraqi Freedom."

He added that he had "not discovered any credible evidence of unlawful or improper

activity, yet the allegations persist." He nevertheless asked the OIG to review "whether

the personnel assigned to the Office of Special Plans, at any time, conducted

unauthorized, unlawful or inappropriate intelligence activities."

(U) On September 22,2005, Senator Carl Levin wrote in his capacity as Ranking

Member of the Senate Armed Services Committee (SASC), asking the OIG to expand the

scope of the review requested by Chairman Roberts. Specifically, Senator Levin

requested that "you include all elements of the Office of the Under Secretary of Defense

for Policy, including the Policy Counter Terrorism Evaluation Group (PCTEG) and the

Policy Support office." He posed a number of questions for the 01G to an~wer.~

(U) In fact Senator Levin had already published his own conclusions on this

matter nearly a year before the OIG took up its review. See "Report of an Inquiry Into

the Alternative Analysis of the Issue of an Iraq-a1 Qaeda Relationship" (October 2 1,

2004), containing numerous incorrect allegations of improper conduct within OUSD(P).

(U) SSCI Report, p. 363.

(U) SSCI Report, p. 3 12.

7 (U) At Appendix B attached to these comments, we address in detail the Draft Report's answers to

Senator Levin's questions.

That report was part of the "minority inquiry" that Senator Levin has been pursuing into

the subject matter of this Project since June 2003, without the endorsement of the SASC,

the SSCI, or any other congressional committee as of early January 2007. The Draft

Report (page 1) comments that Senator Levin's report "challenged some of the

conclusions" in the SSCI's report of July 2004 but fails to note that Senator Levin

himself, as a SSCI member, concurred in that same SSCI report and that the SSCI report

was unanimous.

(U) It bears emphasis that the same set of facts and documents have been available

to the SSCI and to Senator Levin throughout this process.

(U) More recently, on December 8,2006, Representative Cynthia McKinney

introduced articles of impeachment against the President of the United States, the first

article of which makes the false assertion that the President and the Secretary of Defense

created the OSP "to override existing intelligence reports by providing unreliable

evidence that supported the claim that Iraq's alleged weapons of mass destruction posed

an imminent threat to the United States of ~merica."'

(U) Meanwhile, uninformed and inaccurate press reports have persisted, generally

on the theme that the Office of Special Plans allegedly conducted a rogue intelligence

operation before the Iraq war and fed incorrect or exaggerated intelligence information to

senior policy makers in the Executive Branch, bypassing the Intelligence Community and

contributing to an ill-informed decision to go to war in Iraq. These stories have been

repeated so many times that they are now taken as established truth by some members of

Congress and many commentators.

(U) Indeed, even the Draft Report to some extent seems to fall prey to the hypnotic

effect of these constantly repeated falsehoods. Instead of setting the record straight

clearly and directly, the Draft Report relegates to a footnote (at page ii, repeated at page

1) the peculiar comment that:

"The term Office of Special Plans has become generic terminology for the

activities of the OUSD(P), including the Policy Counter Terrorism Evaluation

Group and Policy Support Office. The actual Office of Special Plans had no

responsibility for and did not perform any of the activities examined in this

review."

(U) As the facts detailed below demonstrate, neither the OSP, the PCTEG, nor the

Policy Support Office had any responsibility for the activities reviewed, and none of

these units as such performed any of those activities. The Draft Report should say so

forthrightly.

8 (U) H. Res. 1106, 109'~ Cong., 2"* Sess. (8 December 2006).

(U) The Draft Report should also say prominently and forthrightly that the most

senior leaders of DoD d.irected these activities to be done by non-IC OSD staff members,

not all of whom were even assigned to OUSD(P), rather than repeatedly

mischaracterizing these actions as "OUSD(P)" activities.

(U) These and other deficiencies of the Draft Report, discussed in these comments,

demonstrate that the OIG should reconsider its excursion into the policy and political

issue of whether the lawful and authorized activities under review were "appropriate."

111. OUSD(P) SUPPORT TO THE OIG REVIEW (U)

(U) To assist the OIG in its review, this office provided copies of the thousands of

pages of documents that we had already provided to the SSCI and to Senator Levin. We

also provided various additional materials that the OIG requested. In addition, we

arranged for the OIG to review certain documents that DoD had earlier declined to

provide the Congress. We offered OIG the opportunity to review some ten file boxes

containing all the documents we had collected in the course of our initial search in

response to the SSCI's and Senator Levin's document requests, including documents that

on review we had determined to be unresponsive and thus did not provide to Congress.

We also provided all witnesses that we were in a position to produce for interviews

requested by the OIG and suggested various additional individuals as possible witnesses.

IV. FACTS (U)

(U) Because of the need for a clear, complete and accurate account of the relevant

facts, we provide a detailed statement of facts below. Throughout the factual narrative,

we undertake to highlight the more significant factual errors in the Draft Report.

(U) A discussion section, examining the authorities and analysis set out in the

Draft Report, follows the statement of facts.

(U) The Draft Report does not explain the origin or context of the work under

review. By persistently mischaracterizing this work as "OUSD(P)" activities, the Draft

Report conveys an incorrect impression that this work was an "OUSD(P)" initiative

constituting an "inappropriate" intrusion into "intelligence functions that are the

responsibility of Defense Intelligence" (page 14). The Draft Report mentions that "some

of the actions were performed. in response to inquiries from the Deputy Secretary of

Defense and direction from the Secretary of Defense" (page 13), leaving the incorrect

impression that such actions were somehow incidental to other (unspecified) actions

attributable solely to the "OUSD(P)."

(U) In fact, all (not some) of the work characterized by the Draft Report as

"inappropriate," specifically, three versions of a draft briefing on links between Iraq and

al-Qaida and an internal staff memo done in preparation for the briefing, was in response

to requests and taskings by either the Deputy Secretary or the Secretary of Defense. The

Deputy Secretary directed that the draft briefing be prepared for the Secretary. After the

Secretary received the 'draft briefing, he directed that it be shared with the DCI. When

the Deputy National Security Advisor requested the draft briefing, the Deputy Secretary's

office directed that it be given to him. Three OSD staff members had the primary

responsibility to do this work. Two happened to be DIA analysts detailed to OUSD(P)

and the third worked directly for the Deputy Secretary as his Special Assistant.

(U) How and why these particular three individuals became involved in this work

were as follows:

A. Three Separate Activities Relating to the Work Under Review (U)

(U) There were three, initially separate, activities within the Office of the

Secretary of Defense (OSD) that relate to the work under review in this Project. Some of

the individuals involved in these three activities, and some strands of their work,

eventually came together under the direction and oversight of the Deputy Secretary of

Defense (DSD), who tasked certain work discussed below. That work, and certain

resulting draft documents (critiquing IC work on the Iraq-al-Qaida relationship), are the

actions that the Draft Report mischaracterizes as "alternative intelligence assessments"

and "Intelligence Activities."

(U) In its "Background" section the Draft Report discusses the OSP (page 3) but

fails to make clear in the text that the OSP had nothing to do with any of the activities

under review. None of this work or the resulting documents was done by, for, or under

the direction of the OSP. The work reviewed in this Project was substantially completed

before the OSP even came into de facto existence in mid-August 2002. (The Draft

Report states that OSP was created in October 2002; it was in that month that certain

formalities were implemented.) The Draft Report also errs in stating that the OSP was

"disbanded" in July 2003. In fact it was merely renamed as the Office of Northern Gulf

Affairs, remaining in NESA as before, and its personnel continued to perform their policy

functions regarding that region.

(U) Likewise, none of this work or the resulting documents was done by, for, or

under the direction of the PCTEG or the Policy Support Office as such.

(U) Nor did the Under Secretary of Defense for Policy ever approve or adopt any

of the draft opinions or conclusions in any of the resulting documents as OUSD(P)

positions, views or conclusions.

1. The PCTEG (U)

(U) The first activity relevant here was an ad hoc group, formed by the Under

Secretary of Defense for Policy (USDP) shortly after the 911 1 attacks. The mission of

that group was to review all available information about a number of international

terrorist organizations with a basic focus on the question: What does it mean to be at war

with a terrorist n e t ~ o r k ? ~ The Draft Report erroneously states that this group was formed

"to conduct an independent analysis of the al-Qaida terrorist network" (page 2). In fact,

the group's work was not limited to al-Qaida but addressed more generally various major

terrorist groups and their relations with their state sponsors. This group commenced

work in approximately October 2001 with two members: a consultant, and a detailee

from the Defense Threat Reduction Agency. The group requested and received relevant

intelligence information from the Intelligence Community and did preliminary work on

the subject assigned. Both members, however, left for other duties towards the end of

2001 and the beginning of 2002. Neither of them ever worked in or took direction from

the OSP or the Policy Support Office.

(U) In January 2002 the USDP decided to continue the project in a more formal

way, by naming .the project the "Policy Counter Terrorism Evaluation Group" (PCTEG)

and formally requesting detailees from DIA. The memo approving creation of the

PCTEG described its task as follows:

(U) Study al-Qaida's worldwide organization including its suppliers, its relations

with States and with other terrorist organizations (and their suppliers).

(U) Identify "chokepoints" of cooperation and coordination.

(U) Identify vulnerabilities.

(U) Recommend strategies to render the terrorist networks ineffective.''

(U) Also, as early as January 2002, the Deputy Secretary among others was raising

questions about possible links between Iraq and the al-Qaida terrorist network." In

addition to the information and analyses he regularly received through established

9 (U) Statement of Douglas J. Feith, Under Secretary of Defense for Policy, on the Policy Counter

Terrorism Evaluation Group, before the Select Committee on Intelligence, U.S. Senate, 10 July 2003,

USDP and Senator Levin Correspondence, November 03-July 05, Tab 14.

10 (U) Memo from ASD (ISA) to USDP (3 1 January 2002), USDP Congressional Correspondence

November 02-February 04, Tab 1 8.

11 (U) Memo from DSD to USDP (22 January 2002), reproduced as Appendix E to the Draft Report.

intelligence channels, the Deputy also asked for input from OUSD(P), including in a

memo to the USDP on January 22, 2002.12 He received a reply from the Assistant

Secretary of Defense for International Security Affairs on January 24,2002, summarizing

information suggesting "few direct links" and other information "suggesting more robust

indirect links."13 There was nothing unusual or improper about this. How to assess the

information provided by the IC and what, if any, decisions to make or conclusions to

draw from it are central responsibilities of the Deputy and other senior policy officials of

the Defense Department. It was not remarkable that the Deputy consulted OSD policy

offices as well as the IC on possible links between Iraq and al-Qaida.

(U) In February 2002 USDP requested the Director of DIA to provide three

detailees to the PCTEG.'~ In response, DIA provided two of the three individuals

requested, both reserve Naval intelligence officers then assigned to the 5-2. Contrary to

the Draft Report (page 2), these officers were not detailed to OUSD(P) in October 2001;

rather, they were detailed in February 2002, as replacements for the two original

members of the PCTEG who were gone by the time the two DIA detailees arrived. One

of these DIA detailees departed in April 2002, leaving only one member of the "group,"

who continued to work as the sole member of the PCTEG until he was demobilized from

Naval reserve duty in January 2003. l5

(U) The PCTEG member who departed in April 2002 never worked in or took

direction from .the OSP or the Policy Support Office, nor did the sole remaining PCTEG

member at any time relevant here.16

(U) As originally conceived, the PCTEG was to function under the joint

chairmanship of the Principal Deputy Assistant Secretary of Defense for SOILIC and the

Deputy Assistant Secretary of Defense for NESA'? (not by the ASD (ISA) and ASD

(SOILIC) as the Draft Report incorrectly implies at page 2). But the group never had

l2 (U) Ibid.

l3 (U) Memo from ASD(1SA) to DSD (24 January 2002), reproduced as Appendix F to the Draft Report.

14 (U) Memo for Director, Defense Intelligence Agency (2 February 2002), ibid.

l5 (U) Roster of PCTEG and Special Plans/Northern Gulf, USDP Congressional Correspondence

November 02-February 04, Tab 16A.

l6 (U) After being demobilized from Naval reserve duty in 2003, the former single remaining PCTEG

member did return to OUSD(P) and worked as a civilian in OSP for a time, but that was after the work

relevant to this Project had been completed.

17 (U) Memo from ASD (ISA) to USDP (3 1 January 2002), USDP Congressional Correspondence

November 02-February 04, Tab 18.

more than two members and soon dwindled to one; thus it never attained the degree of

operational formality implied by this nominal joint chairmanship. When the DSD began

to take a more active role on the specific issue of the relationship between Iraq and al-

Qaida, as discussed below, the single remaining member of the PCTEG participated with

others in replying to DSD taskings and at times responded directly to the DSD in that

regard. At no time did the PCTEG report to or take direction from the OSP or the Policy

Support Office.

(U) The PCTEG produced a 154-page draft briefin entitled "Understanding the P Strategic Threat of Terror Networks and their ~~onsors,"' which was revised and

updated periodically. Consistent with the mission of the PCTEG, this briefing examined

the methods and operations of various terrorist organizations (including but not limited to

al-Qaida), the nature of their ties with their state sponsors, and various policy

considerations on dealing with the threat posed by these groups.

(U) This briefing was the sole substantive work product by the PCTEG as such.

The briefing was separate from the work, addressed in the Draft Report, on the specific

issue of the Iraq-al-Qaida relationship.19 The PCTEG briefing was an internal Policy

staff-level product that was never presented outside the Policy organization and never

approved by senior policy makers as an official OUSD(P) position, so far as any facts

known to us are concerned, and the Draft Report does not contend otherwise. Indeed, the

Draft Report only briefly mentions but does not discuss this solitary PCTEG product.

(U) The Draft Report mischaracterizes events in stating (page 3) that the one

remaining PCTEG member created a briefing in the summer of 2002 on links between

Iraq and al-Qaida "with the assistance of a member of OUSD(P)'s Policy Support Office

and a Special Assistant to the Deputy Secretary of Defense." Here and throughout, the

Draft Report ignores or downplays the central fact that the Deputy Secretary of Defense

directed the work to be done, as discussed more fully below. He gave the assignment

initially to his Special Assistant, not to the sole PCTEG member or the Policy Support

Office staffer or anyone else in OUSD(P). The latter two individuals did participate in

responding to the Deputy Secretary because of the circumstances explained in these

comments. But it is a gross distortion to suggest, as the Draft Report does, that the sole

PCTEG member originated this effort or that it was an OUSD(P) activity.

(U) The Draft Report also mischaracterizes events in stating (at page 3) that

"OUSD(P) dissolved the PCTEG shortly" after the draft briefing was given to the Deputy

'* (U) Ibid, Tab 1 5.

19 (U) Although this PCTEG briefing was separate from the work on the specific issue of the Iraq-al-

Qaida relationship done elsewhere in OSD, it obviously overlapped to a degree and eventually led to the

one remaining PCTEG member's being included in the work on that single issue.

National Security Advisor and the Vice President's Chief of Staff in September 2002.

There was no formal action dissolving the PCTEG; rather, the "group" withered away

when its sole remaining member was demobilized from Naval reserve duty in 2003.

2. The DIA Analyst Detailed to the Policy Support Office (U)

(U) The second activity relating to the work under review was begun by a career

DIA analyst whom DIA had detailed, in January 2002, to the former Policy Support

Office of the Deputy Under Secretary of Defense (Policy Support) in OUSD(P). At no

time did this detailee work in or take direction from the OSP or the PCTEG.

(U) DIA detailed this analyst in response to the USDP's by-name request.

Although the Draft Report states (page 2) that the Policy Support Office requested this

DIA analyst due "to the voluminous amounts of intelligence the office was receiving but

was unable to assess," the quoted phrase does not appear in USDP's request. This

analyst was a 25-year intelligence veteran who, at the time of USDP's request, was

assigned to the Interagency Damage Assessment Team for the Robert Hanssen case. This

analyst had had previous experience, inter alia, providing intelligence support to policy

levels as well as experience in Foreign Denial and Deception analysis that the USDP

needed to support certain intelligence-related duties then assigned to the Policy Support

( This analyst was tasked in the Policy Support Office to provide policy

support for special access programs and to carry out other duties requiring a review of

various intelligence products. Sometime in early 2002, in the course of her work, she

came across a finished 1998 CIA report on Iraq's 3

. The report mentioned that Usama Bin Laden had requested and received certain

training from an Iraqi service. On her own initiative, she requested and

received through CIA channels the underlying information on which the item was based,

consisting of two Memo Dissems, and subsequently obtained additional CIA reports from

DIA and CIA on the issue of Iraq and a l - ~ a i d a . ~ ~

(U) As this was the only reporting that this analyst had seen on Bin Laden in this

connection, and because she considered it important data for a discussion on Iraqi

intelligence and al-Qaida, she wrote a one-page "assessment" (in her words) of the IC

reporting and gave it to the DUSD (PS), ASD (ISA), USDP, and DSD."

20 (U) Memo from USDP to Director, DIA (23 November 2001), USDP CongressionaI Correspondence

November 02-Februa y 04, Tab 17; Memorandum for the Record (30 October 2002), ibid.

21 (U) Memorandum for the Record (17 April 2002), Memorandum for the Record (30 October 2002),

USDP Congressional Correspondence November 02-Februu y 04 Tabs 17 and 18.

22 (U) Memorandum for the Record (17 April 2002), ibid at Tab 17

(U) Again on her own initiative, in early spring 2002 the analyst met with the chief

of DIA's Joint Intelligence Task Force for Combating Terrorism (JITF) and gave him a

copy of the reference in the finished CIA report, the two underlying reporting documents,

and her one-pager. (This one-pager should not be confused, as the Draft Report seems to

do, with a later, July 25,2002 internal memo that this analyst wrote in preparation for the

August 2002 briefing to the Secretary of Defense, discussed below.23) She recommended

that the JITF publish the IC reporting data "so that it would be available to the entire IC

because reports published previously did not contain this important data" and that,

without it, "analysis of the subject would be incomplete and inaccurate in the fut~re."'~

Over the next two weeks she spoke twice with the JITF chief, who told her he had given

the materials to the J-2's senior analyst but had heard nothing back.

(U) The analyst then called the J-2's senior analyst and again recommended that

the IC reporting information be published to ,the entire IC. The J-2 analyst responded that

"putting it out there would be playing into the hands of people like Wolfowitz," that the

information "was old" and "only a tid-bit," asked how did she "know that the information

was true," made a comment about trying to support "some agenda of eople in the

building," and bucked the issue of publication back to the JITF chief! The JITF took no

further action on the recommendation to publish the information, so far as we know.

(U) Meanwhile, the DIA analyst detailed to the Policy Support Office continued to

gather and review CIA material on Iraq and al-Qaida. At some point in April or May

23 (U) The Draft Report (page 8) states that this analyst attempted but failed to persuade the JITF Director

and the 5-2's senior analyst to publish as an "Intelligence Finding" a July 25,2002 memo, entitled "Iraq

and al-Qaida: Malung the Case." The July memo was an internal document that she wrote in preparation

for the SecDef briefing, as discussed more fully below. Nothing in the record known to us indicates any

attempt to obtain IC concurrence with the content of the July 25,2002 memo, nor was there any

requirement to do so. Comments to that effect in the Draft Report seem to be a mistaken reference to the

earlier effort, in the spring of 2002, to persuade the IC to publish intelligence reports the analyst had

found about Iraqi training provided to Bin Laden. The Draft Report claims that "OUSD(P) proceeded to

disseminate" the briefing to the SecDef despite being "unsuccessful in convincing the Intelligence

Community to publish the alternative intelligence assessments as an Intelligence Finding." This claim is

wrong. There was no attempt to get the IC to publish "alternative intelligence assessments," there was no

requirement to do so, there was no requirement for IC concurrence on the briefing the DSD had directed

to be given to the SecDef, and neither the July memo nor the August 2002 briefing contained any

"alternative intelligence assessment."

24 (U) Memorandum for the Record (1 7 April 2002), USDP Congressional Correspondence November

02-February 04, Tab 17.

25 (U) Ibid. Judging from this response, the J-2's senior analyst may have been unfamiliar with DIA's DI

Policy No. 005 (5 June 2001), the first sentence of which states, "Curiosity and integrity are the hallmarks

of good analysis."

2002, she became aware of the broader work by the PCTEG on various terrorist

26 organizations.

3. The Deputy Secretary's Tasking to Brief the Secretary of Defense (U)

(U) Soon thereafter, in approximately July 2002, the DSD initiated the third strand

of work relevant here - the strand that resulted in the activities labeled as "inappropriate"

in the Draft Report. Specifically, the DSD directed his Special ~ s s i s t a n t ~ ~ to prepare a

briefing for the Secretary of Defense on Iraq and links to al-Qaida, based on a review "in

a different framework" of IC reports on connections between al-Qaida and ~ r a ~ . ~ ' In

particular, this review was motivated by the issue of whether there was any a priori

reason to believe that ideological opponents, (e.g., secular Iraqi Baathists and Islamic

extremists) would never cooperate against a common foe. By this point in time, the

DSD's Special Assistant, the DIA analyst detailed to the Policy Support Office, and the

single remaining member of the PCTEG had all become aware of the separate but related

work of each. Accordingly, the three of them collaborated in preparing the briefing for

the Secretary of Defense as directed by the DSD.

(U) The record does not support the Draft Report's assertion (page 12) that the

Deputy Secretary asked for an "intel briefing" when he tasked his Special Assistant to

prepare the briefing for the Secretary on Iraq and al-Qaida. That characterization only

appears in an internal e-mail, the author of which was not present when the Deputy gave

the tasking and had no personal knowledge of how the Deputy in fact formulated his

instruction^.^^

(U) The Report makes much of an internal July 25,2002 memo entitled "Iraq and

al-Qaida: Making the Case." This memo is dated after its author, the DIA detailee to

Policy Support, learned of DSD's instruction to his Special Assistant to prepare the

briefing for the Secretary of ~efense" and, according to its author, was done preliminary

26 (U) Memorandum for the Record (30 October 2002), USDP Congressional Correspondence November

02-February 04, Tab 18.

27 (U) DSD's Special Assistant at the time was an individual detailed to DSD from the Policy

organization. At all relevant times this Special Assistant reported directly to, and took direction

exclusively from, the DSD. At no time did the Special Assistant work in or take direction from the OSP,

the PCTEG, or the Policy Support Office.

28 (U) Explanatory Note to E-Mail of 7/22/02, USLIP Congressional Correspondence November 02-

February 04, Tab 17.

29 (U) Ibid.

30 (U) E-mail dated July 22,2202, USDP Congressional Correspondence November 02-February 04, Tab

17.

to that briefing.31 The Report asserts (page 6) that this memo constituted an

"OUSD(P). . . alternative intelligence asse~sment."~' The Report claims that there was

then a "translation of that alternative intelligence assessment" into the briefing for the

Secretary of Defense, which "translation" the Draft Report characterizes (page 6) as an

"Intelligence Activity, and more specifically, Intelligence Production" on the part of

OUSD(P).

(U) To the contrary, the July 25,2002 memo was not an "OUSD(P)" assessment

of any sort, let alone an "alternative intelligence assessment." Nor was it an "Intelligence

Finding" as the Draft Report misleading implies (page 6). It was, rather, a staff-level

memo containing only two introductory paragraphs of commentary, followed by a list

summarizing various IC reports on contacts between Iraq and al-Qaida.

(U) The Draft Report erroneously asserts (page 9) that the memo described these

as "known" contacts. It does not. The phrase "known contacts" does not appear in the

memo.

(U) The two introductory paragraphs of the July 25 memo read as follows:

(U)33 Some analysts have argued that Usama Bin Laden would not

cooperate with secular Arab regimes such as Iraq because of differences in

ideological and religious beliefs. Reporting indicates otherwise. In fact, a

body of intelligence reporting for over a decade from varied sources reflects a

pattern of Iraqi support for al-Qaida activities. The covert nature of the

relationship makes it difficult to know the extent of that support. Moreover,

intelligence gaps exist because of ... Iraq's need to cloak its activities, thus

preventing collection of information on additional contacts between Iraq and

al-Qaida.

(u)" Published intelligence analyses continue to suggest that ties

between Iraq and al-Qaida are not "solid" or "provable." Intelligence

31 (U) Letter from USDP to Hon. Pat Roberts (June 29,2004), USDP Congressional Correspondence

March 04-August 04, Tab 30.

32 (U) In contrast, the DL4 Senior Intelligence Analyst in the JITF-CT said that the memo had "no

intelligence value" because, in the words of the Draft Report, it "contradicted the Intelligence Community

assessments.. . ." (Draft Report page 9).

33 (U) The original version of this paragraph was classified. The classified information has been omitted

and the paragraph declassified accordingly.

34 (U) The original version of this paragraph was classified because of content in the bullets that followed

it. Those bullets have been omitted here, and the paragraph declassified accordingly.

assessments do not require juridical evidence to support them. Legal

standards for prosecution needed in law enforcement do not obtain in

intelligence assessments, which look at trends, patterns, capabilities, and

intentions. Based on these criteria, the following information clearly makes

the case for an Intelligence Finding - that Iraq has been complicit in

supporting al-Qaida terrorist activities."

(U) The Draft Report does not define the term "intelligence assessment," and we

are not aware of a commonly accepted definition. But it is apparent that the abovequoted

paragraphs are merely making an argument that the Intelligence Community

should make an "Intelligence Finding" that Iraq had been complicit in supporting al-

Qaida terrorist activities. Considering the far more explicit statements to Congress about

Iraqi assistance to al-Qaida by the Director of Central Intelligence (DCI) himself,

discussed below, the quoted comments by DIA's detailee to Policy hardly seem extreme.

In any case they do not rise to the level of an "intelligence assessment" by the

"OUSD(P)" or an "Intelligence Finding" by anyone.

(U) The Draft Report asserts (page 8) that "OUSD(P) disseminated alternative

intelligence assessments without Intelligence Community consensus to senior decisionmakers."

The Draft Report asserts (page 8) that OUSD(P) should have followed

procedures contained in DIA's DI Policy No. 005 (5 June 2001), which allegedly

"detailed appropriate methods within Defense Intelligence for addressing alternative

judgments in those rare instances where consensus could not be reached."

(U) These assertions are wrong. Apart from the fact that the work was not

"OUSD(P)" assessments and not in any case "intelligence assessments," the Draft Report

ignores the fact that the Deputy Secretary had asked for a critical reading by non-IC staff

members of assessments already provided by the IC. He had not asked for an alternative

intelligence judgment and specifically directed that a "consensus" with the IC was not the

purpose of this work. As the Deputy wrote in a memo after the briefing to the Secretary:

"That was an excellent briefing. The Secretary was very impressed. He asked us

to think about some possible next steps to see if we can illuminate the differences

between us and the CIA. The goal is not to produce a consensus product, but

rather to scrub one another's arguments" (emphasis in original).36

(U) It would have been contrary to the Deputy's direction, not to say futile, for the

staffers doing this work to have sought an IC consensus on what was specifically

35 (U) The full text of the July 25,2002 memo is attached as Tab 2 to Letter from USDP to Hon. Pat

Roberts (June 29,2004), USDP Congressional Correspondence March 04-August 04, Tab 30.

36 (U) Memo from Paul Wolfowitz to Tina Shelton, et al. (8 August 2002), USDP Congressional

Correspondence November 02-Februaly 04, Tab 17.

intended as a critique of IC work, not as a competing "intelligence assessment." Yet ,the

OIG apparently believes that it would have been more appropriate for these staff

members to have disregarded the Deputy's direction.

(U) Even if the objective had been to obtain an "alternative intelligence judgment"

from the IC, which the Draft Report inexplicably seems to say was or should have been

the case, neither DI Policy No. 005 nor DI Policy No. 004 (also cited by the Draft Report)

provides any procedure whatever for the DIA's customers to obtain such an alternative

judgment. Both documents are confined solely to situations in which a DIA analyst,

working as such within DIA, wishes to put forward an alternative analysis or alternative

judgment through DIA's chain of command. In the present case, one of the individuals

responding to the Deputy's tasking had no connection with DIA at all, and the other two

were working in policy positions on detail to OUSD(P). There is no factual or legal basis

for the Draft Report's assertion that these internal DIA policies continued to apply to

these detailees while assigned to OUSD(P). The full texts of these internal DIA policies

are attached at Appendix A.

(U) The Report claims (page 8) that the DIA detailee who wrote the July 25,2002

memo "requested first from the Director of the Joint Intelligence Task Force for

Combating Terrorism (JITF-CT) and then the Joint Staff 52's Senior Analyst to publish

the alternative intelligence assessment as an 'Intelligence Finding,"' rather than using

"the standard process of coordinating to obtain consensus from the Intelligence

Community" or to "follow the procedures for developing an Alternative Judgment."

Apart from the mischaracterization of this memo as an "alternative intelligence

assessment," the Draft Report lends great weight to this supposed failure in obtaining IC

concurrence, stating (page 8) that "OUSD(P) proceeded to disseminate the August 2002

briefing" to the Secretary though having been "unsuccessful in convincing the

Intelligence Community to publish the alternative intelligence assessments as an

Intelligence Finding."

(U) As noted above, this comment may be a mistaken reference to an earlier

unsuccessful attempt by the DIA detailee to persuade the JITF to publish intelligence

reports she had found on certain training provided to Bin Laden by Iraqi services.

Whether or not the memo's author attempted to coordinate it with the JITF or 5-2, there

was no requirement to do so since the memo was an internal Policy staff product done in

preparation for a briefing that the DSD had directed his staff to prepare for the Secretary

of Defense.

(U) It bears emphasis that the DSD gave this direction to his staff, not to the

Intelligence Community, as discussed above. Presumably the OIG has interviewed the

former DSD to explore his reasons for so doing, though the Draft Report does not

eluci.date this. The written record seems clear, however, that the DSD was not seeking to

have the IC publish an "Intelligence Finding" and was expressly not trying to produce a

consensus product with the IC. Rather, he wanted a critique from a policy perspective of

information already provided by the Intelligence Community, followed by an exchange

of views with the IC to see how the various arguments might hold up in the give and take

of vigorous debate.

B. Draft Briefing to the Secretary of Defense (U)

(U) The briefing, marked "draft," was given to the Secretary on August 8,2002~~

and became the first of three versions of the briefing as explained below, all of which

were marked as "Draft" or "Draft Working Entitled "Assessing the

Relationship Between Iraq and a1 Qaida," the briefing summarized existing intelligence

products and traffic on contacts between Iraq and al-Qaida. The briefing asked but did

not directly answer the following "Key Questions":

(U) "What is the probability that there are contacts between Iraq and a1

Qaida?"

(U) "What is the probability that there is cooperation regard.ing such

support functions as finances, expertise, training and logistics?"

(U) "What is .the probability that Iraq and a1 Qaida actually coordinate on

decisions or operations?"

(U) "What is probability that if a relationship existed, Iraq and a1 Qaida

could conceal its depth and characteristics from the United States?"

The briefing then identified various areas of activity in which Iraq and al-Qaida might

have an incentive to cooperate, and for each area summarized the available intelligence

relating to Iraq's and al-Qaida's actions in those areas over time.

(U) One slide entitled "What Would Each Side Want From a Relationship?" lists

several categories of potential Iraqi and al-Qaida objectives that each side might help the

other in fulfilling (e.g., training, financing, disruption of Kurdish opposition, etc.). It is

specifically in regard to these categories that the briefing slide stated "Intelligence

indicates cooperation in all categories; mature, symbiotic relationship."

37 (U) Memo from Paul Wolfowitz to ~ i n a Shelton, et al. (8 August 2002), USDP Congressional

Correspondence November 02-February 04, Tab 17.

38 (U) All three versions of the briefing are attached to Letter from USDP to Hon. Carl Levin (25 March

2004), USDP and Senator Levin Correspondence, November 03-July 05, Tab 9.

(U) The Draft Report (page 6) misquotes this slide by transforming the subjunctive

question in the slide's title ("what would each side want.. .?") into an unconditional

assertion of "what each side wants from a relationship."

(U) Contrary to the Draft Report's mischaracterizations (e.g., page 8), the briefing

did not assert that intelligence indicated cooperation in all categories of possible endeavor

or a mature, symbiotic relationship in all respects, and "OUSD(P)" most certainly never

so contended. No category listed on this slide, and nothing elsewhere in any version of

the draft briefing, referred to cooperation in the conduct of specific terrorist operations or

to cooperation in operations of any sort.

(U) Here and throughout, the Draft Report misstates what the draft briefing said.

It overstates the briefing's caveated observations as "assessments" and "conclusions,"

always arbitrarily attributed to "OUSD(P)."

(U) The whole thrust of the draft briefing was to examine the question, in response

. to DSD's tasking, whether existing intelligence might suggest alternative interpretations

if one assumed that Iraq and al-Qaida might be willing to cooperate in a relationship that

both would have compelling reasons to hide, and to ask what each side might want from

such a relationship.

(U) The question was pertinent because a contrary assumption underpinned a

considerable part of the IC analysis, namely, that Iraq's secular Baathist regime and

Islamic extremists such as al-Qaida would not cooperate because of their ideological and

religious differences. The Draft Report fundamentally errs in failing to review the draft

briefing in the light of its purpose - to respond to DSD's request for an alternative view

based on an alternative assumption.

(U) Each version of the draft briefing included a slide entitled "Findings." None

of these "findings" asserted cooperation between Iraq and al-Qaida in all possible

categories of endeavors or a mature relationship in general. The "findings" in their

entirety were as follows:

(U) "More than a decade of numerous contacts"

(U) "Multiple areas of cooperation"

(U) "Shared anti-US goals and common bellicose rhetoric

-- Unique in calling for killing of Americans and praising 911 1"

(U) "Shared interest and pursuit of WMD"

(U) "[One indication of13' [One possible indication of140 [Some indications

of possible]41 Iraqi coordination with a1 Qaida specifically related to 911 1"

(U) "Relationship would be compartmented by both sides, closely guarded

secret, indications of excellent operational security by both parties"

(U) The reference to possible "coordination with a1 Qaida specifically related to

911 1" was at no time presented as a conclusion that Iraq and al-Qaida had in fact

cooperated in regard to the 911 1 attacks.

(U) Furthermore, both versions briefed outside the Defense Department were

caveated by the word "possible" in reference to "coordination." And all three versions of

the draft briefing included an additional caveat, in a slide preceding the "Findings" slide,

stating that "jiragmentary reporting points to possible Iraqi involvement" in 911 1 and

previous al-Qaida attacks (emphasis added).

(U) These caveated statements in the draft briefing were not "OUSD(P)"

"assessments" and were not presented as such at any of the three presentations of the

briefing.

(U) The Draft Report errs in its repeated assertion (e.g., page 7) that "OUSD(P)

assessed the Iraq - al-Qaida relationship as having a higher degree of cooperation than

those conclusions supported by the Intelligence Community." As discussed above, the

draft briefing was more conditional and less certain in its discussion of "possible"

cooperation than the Draft Report asserts.

(U) On the other hand, the DCI's statements on the subject - which the Draft

Report does not address - were more robust than the OIG admits. The Draft Report

attempts to portray a wide gulf between the draft briefing's observations and the IC's

assessments by quoting from IC products stating that there are "no conclusive signs of

cooperation on specific terrorist operations" and no "compelling evidence demonstrating

direct cooperation" (page 7). But, as discussed, the draft briefing never asserted that

there was any operational relationship or any cooperation on specific terrorist operations.

(U) In any event the draft briefing was not an "OUSD(P)" assessment of any sort.

Nowhere did any version of the draft briefing state that it presented an "OUSD(P)"

position or assessment, the USD(P) never approved or represented the draft briefing as an

39 (U) Version briefed to the Secretary of Defense.

40 (U) Version briefed to the DCI.

41 (U) Version briefed to the Deputy National Security Advisor.

"OUSD(P)" assessment, the Draft Report cites no facts supporting its repeated assertions

to the contrary, and there are none.

C. The Secretary of Defense's Direction to Brief DCI, Draft Briefing to DCI, CIA

Meeting (U)

(U) After receiving the briefing on August 8,2002, the Secretary of Defense

directed that it be given to the DCI, which was done on August 15,2002 at the CIA.^^

The USDP attended this meeting and was accompanied by two of the authors of the

briefing. At the outset of the meeting the USDP made a statement stressing that this

briefing was merely one way of looking at the underlying information, that no one was

saying it was necessarily the correct way, and that there were also other ways to view the

information. In other words, he made clear that the briefing was for the purpose of

discussion and was not presented as an approved OSD or OUSD(P) position.

(U) The draft briefing as given to the DCI did not include a slide entitled

"Fundamental Problems with How Intelligence Community is Assessing Information"

that was included in the other two versions. This slide criticized the IC for applying an

overly strict "juridical" standard in its assessments of the Iraq-al-Qaida relationship,

underestimating the importance each side would attach to hiding a relationship, and

making an assumption that secularists and Islamists would not cooperate even when they

had common interests. It was omitted from the DCI briefing because its critical tone at

the DCI-hosted meeting might have distracted from a discussion of the substance.43 Even

without the omitted slide, however, it was clear from the overall content that the draft

briefing was suggesting insufficient attention and analysis by the IC to a number of

intelligence reports on contacts between Iraq and al-Qaida - a point that was made

explicitly at a subsequent meeting at CIA on August 20,2002, discussed below.

(U) The reference in the briefing to possible Iraqi coordination with al-Qaida

related to 911 1 was based on a report from the Czech intelligence service that future 911 1

highjacker Mohammad Atta had met with the Prague chief of the Iraqi Intelligence

Service in April 2001. All three versions of the draft briefing, including the one given to

the DCI, had a slide entitled "Summary of Known Iraq-a1 Qaida Contacts, 1990-2002"

that included the statement "2001: Prague IIS Chief al-Ani meets with Mohammad Atta

in April."

( Whether or not it was an overstatement to describe the reported Atta

meeting as a "known contact," the fact is that at the time of this briefing the Czech

intelligence service stood firmly by its report and apparently - 42 (U) SSCI Report, p. 362.

43 (U) Letter from USDP to Hon. Carl Levin (25 March 2004), USDP and Senator Levin Correspondence,

November 03-July 05, Tab 9.

relevant to this Project did the US Intelligence Community articulate and disseminate any

conclusive coordinated judgment that the reported Atta meeting did not occur.

(U) In any case all versions of the draft briefing merely spoke of an "indication" of

"coordination" regarding 911 1 in regard to this alleged meeting, both versions presented

outside the Defense Department added the further caveat of "possible," and no version of

the draft briefing asserted that Iraq and al-Qaida actually cooperated operationally or

otherwise in regard to the 911 1 attacks.

(U) Furthermore, during all times relevant to this Project the question of the

reported Atta meeting was well known and vigorously discussed throughout USG policy

and intelligence circles with responsibility for Iraq. There can be no doubt that all

recipients of the draft briefing, and most particularly the Secretary of Defense, the DCI,

the Deputy National Security Advisor and the Vice President's Chief of Staff, were aware

of the controversy surrounding the alleged meeting. They all were recipients of the IC's

judgments on this and related matters, both before and after receiving the draft briefing.

There is no factual basis whatever to suggest that any of them would have been misled by

anything about this meeting in any version of the draft briefing, or would have

misunderstood the draft briefing to be some sort of "intelligence assessment" by

OUSD(P).

(U) The DCI reportedly found the briefing The DCI asked the

OUSD(P) staffers to speak with the CIA'S NESA and CTC experts on Iraq and terrorism.

As a result, the two OUSD(P) staffers who briefed the DCI were invited to attend an

August 20,2002 meeting of analysts from the CTC, NESA, the National Security Agency

and the DIA who convened to discuss ongoing intelligence community work assessing

Iraq's links to terrorism. At the meeting the OUSD(P) staffers pointed out various

intelligence reports that had not been included in finished intelligence products and

suggested that such reports should be included. Some of their suggestions were adopted

and some were not.

(U) The Draft Report notes (page 10) that in this meeting the "CIA was even

willing to footnote its report with the OUSD(P) conclusions that differed from the

report's findings." In fact, there was no offer to footnote "OUSD(P) conclusions," and in

any case there were no "OUSD(P) conclusions" on the matter at hand, hence none to

44 (U) Memo Entitled "Quick Points on the Policy Team's Visit with DCI" (16 August 2002), USDP and

Senator Levin Correspondence, November 03-July 05, Tab 9.

footnote. Also, the OUSD(P) staffers in attendance did not decline footnotes because

they were "unable to speak for Defense Intelligence" as the Draft Report (page 10) puts

it, although in fact they were not. The actual exchange was simply this: One of the

OUSD(P) staffers (the DIA analyst to the Policy Support Office), when asked to prepare

footnotes on the issues with which she disagreed, declined to do so, stating that "I was an

employee in Policy, not wearing an intelligence hat. I could only ask why reporting was

not included in finished products and . . . make recommendations to include it."45

(U) In its unanimous report on pre-war intelligence issues in July 2004, the Senate

Select Committee on Intelligence stated that all attendees of the August 20,2002 meeting

"interviewed by .the Committee staff (eight of the twelve individuals) agreed that the

OUSDP staffers were not given special treatment[,] . . .their attendance contributed to a

,746 frank exchange of opinions" and they "played by IC rules.. . . The Committee Report

also noted more generally that:

"In some cases, those interviewed stated that the questions had forced them to go

back and review the intelligence reporting, and that during this exercise they came

across information they had overlooked in initial readings. The Committee found

that this process - the policyrnakers probing questions - actually improved the

Central Intelligence Agency's . . . products."47

D. Deputy National Security Advisor's Request, DSD's Direction, Draft Briefing to

Deputy National Security Advisor (U)

(U) The Draft Report mischaracterizes these events as "Dissemination of

OUSD(P)'s Alternative Intelligence Assessment to the White House" page 10). What

transpired is this:

(U) Following a reference to the briefing at a Deputies Committee meeting in

August 2002, the Deputy National Security Advisor requested to receive the briefing.

The Deputy DCI was a designated member of the Deputies Committee, and he or his

designee consistently attended its meetings. On the morning of September 16,2002, the

Deputy Secretary's office instructed the OUSD(P) staffers who had helped prepare the

draft brief to present it to the Deputy National Security Advisor and the Vice President's

Chief of Staff. They did so the same day at a meeting hosted by the Deputy National

Security Advisor in the Situation Room, with the Vice President's Chief of Staff

attending for at least part of the meeting.

45 (U) Memorandum for the Record (30 October 2002), USDP CongressionaI Correspondence November

02-Februaly 04, Tab 17.

46 (U) SSCI Report, pp. 362,363.

47 (U) SSCI Report, p. 34.

2 7

(U) The Draft Report fails to mention that the OUSD(P) staffers gave the

September 16 briefing because they were instructed to do so by the Deputy Secretary's

office in response to the Deputy National Security Advisor's request. The Draft Report

does correctly state (page 29) that there was no requirement for the DCI to be informed of

this meeting. One might reasonably observe that .there was no requirement because the

meeting was not an intelligence meeting.

(U) In any case, this version of the draft briefing, just as the previous two versions,

contained no intelligence assessment and was not presented as an official OUSD(P)

position. It was presented not as an intelligence briefing but as an alternative assessment

of IC reports, just as the prior two versions of the briefing.

(U) The Draft Report states (page 11) that this version of the draft briefing

included a "previously unseen" slide entitled "Facilitation: Atta Meeting in Prague."

The Draft Report fails to point out that the slide was "previously unseen" because it did

not previously exist. The Draft Report incorrectly asserts that this new slide presented

the alleged Atta meeting "as fact" (page 11). Nowhere does the slide describe the

meeting as "fact." To the contrary, the slide repeatedly uses phrases such as "Czech

service reports that Atta visited . . . ," "despite press reports of conflicting information,

Czech Interior Minister . . . stands by previous Czech . . . reporting," "Atta reportedly held

meetings.. . ," and "Atta reportedly arrives in Prague.. . . ,748

(U) Furthermore, the attendees at this version of the draft briefing were well

informed senior officials who had access to all the IC's most highly classified and

compartmented information on tlie subject of the alleged Atta meeting. The Deputy

National Security Advisor and the Vice President's Chief of Staff certainly were familiar

with the debate in the US Intelligence Community on this subject. It is ludicrous to

suggest that they would have mistaken this slide or anything else in the draft brief as firm

assertions of fact, much less as "intelligence assessments" by "OUSD(P)" or anyone else.

E. DCI's Congressional Statements on Iraq and al-Qaida (U)

(U) The Draft Report partially quotes from several IC reports, casting doubt on the

existence of any significant cooperation between Iraq and al-Qaida, in asserting that the

work under review overstated the degree of cooperation and hence "OUSD(P)" did not

provide "the most accurate analysis of intelligence" (page 11). As noted above, the

responsibility to provide "the most accurate analysis of intelligence" rests with the IC, not

OUSD(P). More importantly, senior decision-makers already had the 1C's reports and

assessments on Iraq and al-Qaida and thus already had "the most accurate analysis of

48 (U) USDP and Senator Levin Correspondence, November 03-July 05, Tab 9.

28

intelligence" -- if one accepts, as the Draft Report seems to do, that the IC's assessments

are the "most accurate".

(U) It is puzzling, therefore, that the Draft Report fails to discuss some of the most

authoritative articulations of the IC's analysis on Iraq and al-Qaida - the vetted,

coordinated correspondence and testimony by the DCI himself to the Congress. On

October 7, 2002, the DCI wrote to SSCI Chairman Graham, responding to various

questions raised in connection with the forthcoming debate on a joint resolution to

authorize military action against Iraq. Regarding questions about Iraqi links to al-Qaida,

the DCI wrote that Senators could draw from the following points for unclassified

discussions:

Our understanding of the relationship between Iraq and al-Qa'ida is

evolving and is based on sources of varying reliability. Some of the

information we have received comes from detainees, including some of

high rank.

We have solid reporting of senior level contacts between Iraq and al-

Qa'ida going back a decade.

(U) By comparison, the draft briefing referred to "more than a decade of numerous

contacts. The DCI's letter continued:

Credible information indicates that Iraq and al-Qa'ida have discussed

safe haven and reciprocal non-aggression.

(U) The draft briefing referred to "safe haven of last resort" as an objective that al-

Qaida would want from a relationship with Iraq. The DCI's letter continued:

Since Operation Enduring Freedom, we have solid evidence of the

presence in Iraq of al-Qa'ida members, including some that have been

in Baghdad.

(U) The draft briefing said that "Iraq Has Provided Safe Haven for Key

Terrorists," among them al-Qaida members, including some in Baghdad. The DCI's

letter continued:

We have credible reporting that al-Qa'ida leaders sought contacts in

Iraq who could help them acquire WMD capabilities. The reporting

also stated that Iraq has provided training to al-Qa'ida members in the

areas of poisons and gases and making conventional bombs.

(U) The draft briefing said that Iraq and al-Qaida had a "shared interest and pursuit

of WMD," that "CBRN" would be an al-Qaida objective, and that al-Qaida had sought

bomb-making assistance. The DCI's letter continued:

Iraq's increasing support to extremist Palestinians, coupled with

growing indications of a relationship with al-Qa'ida, suggest that

Baghdad's links to terrorists will increase, even absent military

acti0n.4~

(U) In a prepared statement to the SSCI on February 11,2003, DCI Tenet said:

Iraq has in the past provided training in document forgery and bomb-making

to al-Qa'ida. It also provided training in poisons and gasses to two al-Qa'ida

associates; one of these associates characterized the relationship he forged

with Iraqi officials as successful. Mr. Chairman, this information is based on

a solid foundation of intelligence. It comes to us from credible and reliable

(U) At a Senate Armed Services Committee hearing on February 12,2003, the

DCI stated:

[W]e also know from very reliable information that there's been some

transfer of training in chemical and biologicals [sic] from the Iraqis to a1 ~aeda."

(U) From these statements by .the DCI on behalf of the Intelligence Community, it

is clear that the IC "consensus" at the time ascribed considerably more "maturity" and

"symbiosis" to the relationship between Iraq and al-Qaida than depicted in the Draft

Report. It is also clear that the Draft Report significantly overstates the degree and

significance of inconsistencies between the IC consensus and the draft briefing's

observations. In any case the draft briefing was nothing more than a draft, it was not an

"intelligence assessment," and it was not an "OUSD(P)" assessment or conclusion.

49 (U) Letter George Tenet, DCI, to Hon. Bob Graham, Chairman SSCI (7 October 2002), in E-Mail from

Michael H. Mobbs (OUSDP) to Charles E. Edge (OIG) (7 February 2006), at Tab C.

50 (U) "Administration Statements on Iraq Training a1 Qa'ida in Chemical and Biological Weapons,"

attached to Press Release by Senator Carl Levin Re: Levin Says Newly Declassified Information

Indicates Bush Administration's Use of Pre-War Intelligence Was Misleading (6 November 2005), in EMail

from Michael H. Mobbs (OUSDP) to Charles E. Edge (OIG) (7 February 2006), at Tab C.

51 (U) Ibid.

?O

V. DISCUSSION (U)

A. Why are Lawful and Authorized Activities Nevertheless Called

"Inappropriate"? (U)

(U) The Draft Report concludes that the activities reviewed in this Project were

lawful and authorized (pages ii, 4, 13). It states that within the authority conferred by

Title X, Section 113 of the United States Code, "the Secretary owns the DoD Directives

governing (among others) Intelligence and Policy, and as long as Executive Orders or

other legal statutes are not violated, he has the latitude to interchange roles and

responsibilities" (page 34).

(U) Despite these conclusions, the Draft Report asserts that these same activities

were "inappropriate," in the OIG's opinion, because the "OUSD(P)" "products did not

clearly show the variance with the consensus of the Intelligence Community and were, in

some cases, shown as intelligence products" (page 4).

(U) It is somewhat difficult to understand how activities that admittedly were

lawful and authorized (in this case by either the Secretary or the Deputy Secretary of

Defense) could nevertheless be characterized as "inappropriate" -- particularly

considering OIG's concession that the Secretary (and by logical extension the Deputy)

may interchange roles and responsibilities within DoD provided no statutes or executive

orders are violated. The Draft Report points to no laws, executive orders, DoD

directives, DoD instructions or DoD publications that provide any guidelines for what is

"appropriate" in this case, except for the Secretary's broad mandate under Title X. That

mandate leads to a conclusion that the activities reviewed were "appropriate."

(U) The Draft Report is spare of analysis on why its reaches the opposite

conclusion. The argument seems to be as follows:

(U) DIA detailees to OUSD(P) reviewed the same intelligence information that the

IC had used when drawing IC judgments about links between Iraq and al-Qaida.

This was appropriate for policy formulation (page 12).

(U) Appropriate policy formulation, however, "evolved into Intelligence Analysis

and eventually culminated in the Intelligence Activity of Intelligence Production

with the creation of alternate intelligence assessments and dissemination when the

briefing was provided to the Secretary of Defense, DCI, and members of the

Office of the Vice President and National Security Counsel" (page 12).

(U) This supposed "evolution" was inappropriate because it led to performance by

"OUSD(P)" of "intelligence functions that are the responsibility of Defense

Intelligence" (page 14), the work products "did not clearly show the variance with

the consensus of the Intelligence Community" (page 4), and the work products

"were, in some cases, shown as intelligence products" (page 4).

(U) If "OUSD(P)" did not consider the IC's existing "judgment" about Iraq and al-

Qaida to be correct, "OUSD(P)" should have used "existing procedures" to get a

second IC "judgment" by requesting "from the Defense Intelligence community an

Alternative Judgment" on that subject (page$ 13-14) - instead of participating in

an OSD critique of the existing IC judgment as directed by the DSD. Such

"existing procedures" are said to be found in two internal DIA policies cited in the

Draft Report (DI Policy Nos. 004 and 005).

(U) It is apparent from the above summary that the Draft Report's conclusions

about "inappropriate" activities rest heavily on internal DIA policies dealing with

alternative IC assessments and judgments, as well as Intelligence Community concepts

such as "Intelligence Activities," "Intelligence Production," "Intelligence Analysis," and

"intelligence assessments." An examination of the DIA policies and relevant IC concepts

shows that they do not apply to the activities reviewed here. Thus the assertion that the

activities were "inappropriate" cannot withstand analysis.

(U) Before turning to the analytical errors in the Draft Report, however, we

respectfully point out that the specific reasons on which the Draft Report rests its finding

of "inappropriateness" do not bear scrutiny.

(U) First, the Draft Report claims that the work products were inappropriate

because they "did not clearly show the variance with the consensus of the Intelligence

Community." This fundamentally mischaracterizes the purpose and nature of the work.

The central purpose of these activities was to look critically at existing IC work and offer

a different way of understanding the IC information. Each version of the draft briefing

made this clear. The senior decision-makers briefed on this work (one of whom was the

DCI himself) did not need to be told that it was at variance with the IC in some respects;

that was inescapably obvious. There are no facts to suggest that any of them drew any

conclusions or made any decisions whatsoever solely on the basis of the draft briefing,

without taking IC views into con~ideration.~~

(U) Furthermore, there was no requirement to specify in a draft work product, not

offered as a proposed action item, how it might vary from IC views. The situation would

52 (U) It was not the place of OUSD(P) in any event to articulate what the IC "consensus" was, which

would have been the first step in "clearly show[ing] the variance" as the Draft Report asserts should have

been done. It was up to the IC to articulate its consensus, if it had one. The Draft Report itself shows the

pitfalls of trying to articulate an "IC consensus" for the IC. The Draft Report purports to describe such a

consensus but utterly fails to mention the DCI's vetted, cleared statements to Congress on the Iraq-al-

Qaida relationship. Those statements do not support the Draft Report's characterization of the IC

'6 consensus."

have been different if the draft briefing were put forward in support of some proposed

action or decision, for example, a proposal that the President make a speech to the Nation

describing a relationship between Iraq and al-Qaida. In such a case, the matter would

have been discussed, at the least, by the Deputies Committee. All interested agencies

would have been asked to provide their views, in particular their comments on the draft

briefing and any other material offered in support of or against the proposed speech. The

IC would have had ample opportunity to articulate how its views did or did not vary from

the draft briefing. There would have been no need for "OUSD(P)" to do that; indeed, the

IC would no doubt have objected strenuously to the idea of having another agency

describe how its views might vary from those depicted in the draft briefing. Obviously,

nothing of the sort happened here.

(U) Second, the Draft Report asserts that the work was "inappropriate" because

some of it was "shown as intelligence products." There are no facts whatsoever to

support this statement. The Draft Report only gives one example, the July 25,2002

internal staff memo (done in preparation for the draft briefing), discussed at length in Part

IV above. That memo argued that the IC had sufficient information to make an

intelligence finding that Iraq had been "complicit in supporting al-Qaida terrorist

activities." The Draft Report mischaracterizes this memo as an "OUSD(P)" intelligence

assessment. In fact it was nothing more than a staff member's opinion that the IC should

make an intelligence finding.

(U) Third, the Draft Report considers the work reviewed inappropriate because it

amounted to "intelligence functions that are the responsibility of Defense Intelligence."

We explain below why the work was not "intelligence functions." But even accepting

that characterization for discussion purposes only, the Draft Report in this respect

contradicts its own admission that the Secretary "has the latitude to interchange roles and

responsibilities" in managing the Department so long as no statutes or executive orders

are violated. The Draft Report fails to explain why it was inappropriate for the Secretary

and Deputy Secretary to exercise that latitude in this case. If the OIG believes the

Deputy inappropriately used his latitude to assign this work to non-IC staff members, and

the Secretary and Deputy misused their latitude to direct that those staff members share

this work outside the Department, it is incumbent on the OIG to say so directly and to

explain why it holds this opinion. It is not sufficient for the OIG simply to fault

"OUSD(P)" with engaging in "inappropriate" behavior because two Policy staffers did as

told by the Secretary and Deputy, and let it go at that.

B. DIA's DI Policy Nos. 004 and 005 Do Not Apply to Non-IC Offices Directed by

Senior DoD Leaders to Critique Intelligence Community Work (U)

(U) The Draft Report cites Policy Nos. 004 and 005 developed by DIA's

Directorate for Analysis and Production. These internal policies set out guidelines and

procedures for DIA analysts who wish to propose, respectively, an alternative analysis or

an alternative judgment when they believe that they cannot reach a consensus with other

intelligence analysts on a particular issue. The Draft Report erroneously characterizes

these internal DI policies as "the standard process of coordinating to obtain consensus

from the Intelligence Community" that the DIA detailees to OUSD(P) should have used

in this case (page 8). The Draft Report also erroneously describes these internal policies

as the "existing procedures" (page 14) that OUSD(P) should use to "request that an

Alternative Judgment be produced by Defense Intelligence" if OUSD(P) believes that the

IC is incorrect on a given matter (page 13).

1. The Internal DIA Policies Do Not Apply to DIA Members While Detailed

to Policy Positions Outside DIA's Chain of Command (U)

(U) The texts of these internal DI policies are reproduced in full at Appendix A to

these comments. There is nothing in either of them to support the idea that they continue

to apply to DIA analysts who are detailed to policy positions and who are tasked to do

independent assessments for the express purpose of providing a non-IC critique, or

review, of IC views. It is obvious from the texts that they only apply to analysts working

within the DIA chain of command and proposing alternative assessments or judgments,

in an intelligence capacity, within that chain of command. DI Policy No. 005, for

example, provides that "the analyst forwards . . . through the immediate SupervisorIOffice

Senior Intelligence Officer (SIO) to the Group SIOIResearch Director (RD). The

Supervisors/Office SIOs review . . . for format and completeness. The Group SIOIRD

reviews . . . to ensure it accurately describes the competing analyses," etc. This process

has no relevance to a situation such as the present, where the Deputy Secretary

specifically directed that he wanted an alternative look at the IC's work from outside the

IC and was not seeking to develop a consensus.

2. The Internal DIA Policies Contain No Procedure for an IC Customer to

Obtain an Alternative IC Judgment, Which in any Case is not What the DSD

Sought Here (U)

(U) Neither of these internal DI policies contains any procedure for an IC

customer, such as OUSD(P), to request an "alternative judgment" from the DIA if the

customer considers an existing IC judgment to be incorrect. While the Draft Report

inexplicably allows that OUSD(P) "is not . . . required to await final adjudication or

production of an Alternative Judgment from DIA" (page 13), thus raising the question of

why the "Alternative Judgment" should be sought at all, the fact remains that these

internal DI policies do not provide for a customer to make such a request. One will

search the texts in vain for even the slightest hint of such a procedure.

(U) The very notion that a customer should ask the IC for an alternative

intelligence judgment if it dislikes the judgment already given is bizarre on its face. Such

a request would inevitably bring down a firestorm of criticism that the customer was

attempting to "politicize" intelligence or "pressure" the intelligence analysts into

changing their assessments. In any event, the Deputy Secretary in the present matter

expressed no wish for an "alternative judgment" from the IC, which is undoubtedly why

the staffers responding to his tasking did not seek one. And he expressly directed that the

objective of the work was not to develop a consensus product but rather to see how

competing arguments might stand up in an exchange of views with the IC.

3. The Internal DIA Policies Were Not Coordinated or Published as Would

Have Been Required if Intended to Apply Outside DIA (U)

(U) There is no basis for asserting that the DI internal policies are applicable to

DoD as a whole or to OUSD(P) in particular. To the contrary, these policies have not

been published; they have not been disseminated to OUSD(P) or, so far as we know,

elsewhere in the Department outside DIA; and they have not been presented to OUSD(P)

for review or coordination.

(U) Guidance that is intended to have Departmental applicability falls within the

requirements of DoD Directive No. 5025.1, "DoD Directives System," July 27,2000, as

reissued July 14,2004. Section 4.1 of this directive articulates a DoD policy to maintain

"a single, streamlined, uniform system governing the preparation, coordination, approval,

publication, dissemination, implementation, and internal review of DoD issuances.. . ."

Proposed DoD issuances "shall be formally coordinated to solicit the views of the Heads

of the DoD Components" (Section 4.4). All DoD issuances "must be coordinated with

the General Counsel, DoD, the Inspector General, DoD, and the Director of

Administration and Management" (Section 4.4.1). The Heads of DoD Components

"shall review and coordinate on proposed DoD issuances relevant to their missions"

(Section 5.4).

(U) Nothing of the sort was done with regard to DI Policy Nos. 004 and 005.

They have no applicability to OUSD(P). They are not "existing procedures" that

OUSD(P) should have, or could have, followed in the present matter. The Draft Report's

recommendation that they be followed as "existing procedures" in the future is

unfounded and inappropriate.

C. "Intelligence Activities" Constitute a Process Using All Key Elements of

Intelligence Work By Intelligence Agencies (U)

(U) As the guidance cited by the Draft Report (page 4-5, Appendix H) and other

relevant authorities make clear, "Intelligence Activities" involve the entire process by

which intelligence agencies turn information into a product that intelligence consumers

can use. They do not encompass the type of work reviewed here.

(U) In asserting otherwise, the Report relies primarily on DoD Directive No.

5240.1, "DoD Intelligence Activities, April 25, 1988, and DoD Directive No. 5 105.2 1,

"Defense Intelligence Agency (DIA)," February 18, 1997. Of these, only DoD Directive

No. 5240.1 (Section 3.1) contains a definition of "Intelligence Activities" which is as

follows:

"Intelligence activities. The collection, production, and dissemination of foreign

intelligence and counterintelligence by DoD intelligence components authorized

under reference (b) ."

(U) "Reference (b)" is Executive Order 12333, "United States Intelligence

Activities," December 4, 198 1, Section 3.4(e) of which defines "intelligence activities" as

"all activities that agencies within the Intelligence Community are authorized to conduct

pursuant to this Order." Section 3.4(f) defines "Intelligence Community and agencies

within the Intelligence Community" as "the following agencies or organizations," among

which the Office of the Secretary of Defense and the Office of the Under Secretary of

Defense do not appear.

(U) DoD Directive No. 5240.1, Section 3.4, similarly defines "DoD intelligence

components" as "[all1 DoD Components conducting intelligence activities, including" a

list of named DoD elements among which, again, the Office of the Secretary of Defense

and the Office of the Under Secretary of Defense do not appear. In contrast Section 2.1

of DoD Directive No. 5240.1 does define "DoD Components" to include the Office of the

Secretary of Defense. Thus the Directive carefully distinguishes "all DoD Components"

from "DoD Components conducting intelligence activities." In consequence, the

Directive's Section 3.1 definition of "Intelligence Activities" by its terms only

encompasses "DoD intelligence components," not "all DoD Components."

(U) The above definitions make clear that "Intelligence Activities" constitute a

process that entails collection, production "and" (not "or") dissemination of foreign

intelligence or counterintelligence as conducted by intelligence agencies, and not

assessments or critiques by non-intelligence offices.

(U) Various definitions in Joint Publication 1-02, Department of Defense

Dictionary of Military and Associated Terms (1 2 April 200 1, as amended through 16

October 2006) ("JP 1-02") also demonstrate that the term "Intelligence Activities" should

be understood as a process of actions and operations conducted by the Intelligence

Community to produce an intelligence product for consumers. For example, according to

JP 1-02:

"intelligence" means "[tlhe product resulting from the collection, processing,

integration, analysis, evaluation, and interpretation of available information

concerning foreign countries or areas" (JP1-02 at 268);

"intelligence process" means "[tlhe process by which information is converted

into intelligence and made available to users. The process consists of six

interrelated intelligence operations: planning and direction, collection, processing

and exploitation, analysis and production, dissemination and integration, and

evaluation and feedback" (JP 1-02 at 270); and

"intelligence community" means "[all1 departments or agencies of a government

that are concerned with intelligence activity, either in an oversight, managerial,

support, or participatory role" (JP 1-02 at 269).

(U) None of the above definitions accurately describe the critical assessment of IC

information by OSD staff members that is the subject of this review.

D. Alternative or Critical Assessments of IC Information and IC Judgments by

Non-IC Offices Are Not "Intelligence Activities" (U)

(U) As the above definitions of "Intelligence Activities" and related terms make

clear, such activities consist of the entire process of actions and operations conducted by

intelligence agencies to produce an intelligence product for consumers. It is incorrect to

select one or a few activities that are part of the "intelligence process" and characterize

those selected activities as "Intelligence Activities" even when conducted by non-IC

policy elements of government.

(U) The definitions of "Intelligence Activities" and related terms do not

encompass an alternative or critical analysis, evaluation, interpretation or assessment by a

non-IC office, such as OSD or OUSD(P), of information provided by the Intelligence

Community. In this context, the "analysis," etc. is merely an independent review by a

non-IC organization, or in the present case by several non-IC OSD staffers, of IC

information provided by the IC. In conducting this review, the non-IC organization may

even exercise independent judgment about the meaning or significance of the intelligence

information provided by the IC. This act of independent judgment by the non-IC

organization does not constitute "Intelligence Activities" under any of the above

definitions or any common-sense understanding.

(U) The mere fact that the "intelligence process" conducted by the Intelligence

Community includes but is not limited to "analysis" and "dissemination" does not mean

that a policy organization is conducting "Intelligence Activities" if it independently

"analyses" intelligence information provided by the IC and then "disseminates" the

results of its analysis. To assert such a proposition is akin to asserting that "cows have

four legs and give milk, therefore, all four-legged animals that give milk are cows."

(U) The Draft Report cites the definition of "Intelligence Production" found in

DoD Directive No. 5 105.2 1 in an effort to characterize OUSD(P) activities as

"Intelligence Activities." But the actual definition does not support this argument.

(U) The term "Intelligence Production" as defined in Directive No. 5 105.2 1 does

not apply to any activities under review here. Paragraph E2.1.3 of the Directive provides:

"Intelligence Production. The validation, correlation, analysis, and interpretation

of information on foreign intelligence and counterintelligence topics, including the

use of automated data bases and the presentation and dissemination of .the results."

This definition, just as the related definitions discussed above, makes clear that

"Intelligence Production" is the full process of validation, correlation, analysis,

interpretation, presentation and dissemination. It is a distortion of the definition to assert

that a single activity, such as analysis or interpretation, constitutes "Intelligence

Production."

(U) In the present matter, the draft briefing and work done to prepare it were

nothing more than a critical review of intelligence information already produced by the

IC. The work presented a fresh assessment of how that information might be understood

if certain a priori assumptions about lack of cooperation between secularists and

fundamentalists were avoided. At the very least the work under review involved no

validation or correlation, as those tasks had already been done by the IC as part of its

"Intelligence Production." The attempt to stretch the definition of "Intelligence

Production" to include the critique of IC reports and products by a non-IC office simply

does not work.

E. OUSD(P) Did Not Produce or Disseminate "Intelligence Assessments" or

"Intelligence Analysis" (U)

(U) The Draft Report asserts (e.g., page 4) that the draft briefing on the

relationship between Iraq and al-Qaida and the July 25,2002 memo preliminary to the

briefing were "OUSD(P)" "alternative intelligence assessments," and that this work

"evolved into Intelligence Analysis" (page 12). The work reviewed was not "intelligence

assessments" or "Intelligence Analysis" under any reasonable understanding of those

terms.

(U) Neither the Draft Report, nor any of the authorities mentioned there or here,

defines the term "intelligence assessment." Nor do they define the term "Intelligence

Analysis" despite the Draft Report's use of capital letters. But extrapolating from the

intelligence-related definitions discussed above, it seems reasonable to suggest that

"intelligence assessments" and "Intelligence Analysis" are assessments and analysis by

intelligence agencies about the meaning and significance of information acquired by

them during the six-part "intelligence process" of "planning and direction, collection,

processing and exploitation, analysis and production, dissemination and integration, and

evaluation and feedback" (JP 1-02 at 270). It follows that "intelligence assessments" and

"Intelligence Analysis" are disseminated by intelligence agencies and are clearly

identified as the "assessment" or "analysis" of the issuing agency or intelligence

community. Thus, intelligence consumers will know that they have the "assessment" or

"analysis" of that agency or community on the matter at hand as opposed to someone

else's assessment or analysis.

(U) Nothing of this sort took place in preparing and presenting the draft briefing in

question. As Part IV (Facts) above explains in detail, the July 25,2002 memo was an

internal document done in preparation for a briefing that the Deputy Secretary had

directed his Special Assistant and two DIA detailees working in the Policy organization

to put together for the Secretary of Defense. The memo did not present any "intelligence

assessment" or "intelligence finding" or anything that could reasonably be characterized

in that way. The memo did argue that there was a case to support an "Intelligence

Finding" that Iraq had been complicit in supporting al-Qaida terrorist activities. But this

obviously was a suggestion that the Intelligence Community should make such an

"Intelligence Finding," since neither the memo's author nor OUSD(P), the Deputy

Secretary or the Secretary were capable of making an "Intelligence Finding."

(U) As Part IV above also explains, the draft briefing likewise contained no

"intelligence assessments," "Intelligence Analysis" or anything that could reasonably be

so described. Each version of the draft briefing was marked as "draft" or "draft working

papers." Each time the briefing was given, it was well known to all in attendance that the

briefers were not speaking for the Intelligence Community but, to the contrary, were

presenting an alternative or critical analysis of information provided by the Intelligence

Community. The analysis intentionally took a different approach from some of the IC

analysis, because of the Deputy Secretary's direction to avoid the a priori assumption

that secular Baathists and Islamic hndamentalists would never cooperate and to examine

how the intelligence information might be understood in the absence of that assumption.

It would be preposterous to suggest that the draft briefing was an effort to usurp the role

of the IC, or that anyone was misled into believing that the draft briefing purported to

express "intelligence assessments" or "Intelligence Analysis" on behalf of the IC or

anyone else.

(U) Moreover, whatever the July 25,2002 memo and the draft briefing may have

been, they most certainly were not "OUSD(P)" assessments or conclusions, as the Draft

Report repeatedly asserts. As Part IV (Facts) discusses in detail, these work products

were never described or presented as an approved OUSD(P) or OSD position, all versions

of the briefing were marked "draft" or "drafi working papers," the USDP introduced the

drafi briefing to the DCI stating that it was merely one way of looking at the underlying

intelligence and not necessarily the correct way, and the drafi briefing itself was done at

the Deputy Secretary's direction. The draft briefing and work leading to it were not

initiated by "OUSD(P)," notwithstanding that two of the three authors happened at the

time to be working in the Policy organization on detail from DIA.

(U) The Draft Report seems to argue that the two DIA detailees continued to

function as intelligence analysts even though detailed to OUSD(P) and therefore their

activities in OUSD(P) "constituted intelligence analysis and in at least several cases,

intelligence production, which was not one of USD(P)'s specified functions in DoD

Directive 5 1 1 1.1" (page 6). This contention cannot withstand scrutiny. If it were correct,

OSUD(P) could never obtain intelligence analysts on detail from DIA without

committing "inappropriate" "Intelligence Activities." How to characterize work done by

detailees depends on the substance of what they actually do while detailees, not on the

nature of their duties in their home agencies. As demonstrated above, the work in

question here did not fall within any of the definitions of "Intelligence Activities" and did

not constitute "intelligence analysis."

(U) The Draft Report also seeks to support its claim that OUSD(P) produced

"alternative intelligence assessments" by referring to "confirmation" in interviews that

the DIA detailees "conducted independent intelligence analysis resulting in analytic

conclusions and products" (page 6). According to the contemporaneous written record,

however, at least one of the DIA detailees said that "[alt no point did I prepare an

intelligence estimate or publish anything I had written" during her involvement in the

work under review. In any event, the terminology that individuals in informal interviews

may have used or acquiesced to, advertently or inadvertently, cannot alter the nature of

the work they actually did or did not do. In this case they did not produce or disseminate

"intelligence assessments" or "Intelligence Analysis" on behalf of OUSD(P) or anyone

else.

F. The Relevant Orders and Directives Describe Intelligence Roles and Activities,

They Do Not Proscribe Policy Activities (U)

(U) The Report refers to definitions from DoD guidance dealing with intelligence

agencies and intelligence activities. It endeavors to apply these definitions to policy

activities undertaken for policy purposes within OSD. In so doing, the Draft Report

transforms these definitions into restrictions on what policy offices may appropriately do.

(U) There is no authority to support the view that definitions describing the

activities of intelligence agencies also apply to policy offices, or constitute limitations or

prohibitions on the activities that policy offices may appropriately conduct. To

demonstrate the fallacy of that thinking, one need only return to the relevant definitions.

(U) As discussed above, DoD Directive No. 5240.1 (Section 3.1) defines

"Intelligence Activities" as:

"The collection, production, and d.issemination of foreign intelligence and

counterintelligence by DoD intelligence components authorized under [Executive

Order 123331."

(U) Executive Order 12333, "United States Intelligence Activities," December 4,

198 1, Section 3.4(e), defines "intelligence activities" as "all activities that agencies

within the Intelligence Community are authorized to conduct pursuant to this Order."

Section 3.4(f) defines "Intelligence Community and agencies within the Intelligence

Community" as "the following agencies or organizations," among which, as noted above,

OSD and OUSD(P) do not appear.

(U) DoD Directive No. 5240.1, Section 3.4, similarly defines "DoD intelligence

components" as "[all1 DoD Components conducting intelligence activities, including" a

list of named DoD elements among which, again as noted above, OSD and OUSD(P) do

not appear. But Section 2.1 of DoD Directive No. 5240.1 does define "DoD

Components" to include the Office of the Secretary of Defense. Thus, as also noted

above, the Directive distinguishes "all DoD Components" from "DoD Components

conducting intelligence activities." In consequence, the Directive's Section 3.1 definition

of "Intelligence Activities" by its terms only encompasses "DoD intelligence

components," not "all DoD Components," as discussed above.

(U) The above definitions make two things clear about "Intelligence Activities":

1. They constitute a process that entails collection, production "and" (not

"or") dissemination of foreign intelligence or counterintelligence, and

2. They are activities conducted by intelligence agencies, and not policy or

other assessments or critiques by non-intelligence offices, even if these

activities have similarities with "intelligence activities" performed by

intelligence "agencies" or "components."

(U) The Draft Report in effect expands the definition of "Intelligence Activities"

contained in Directive 5240.1, Section 3.1, by dropping the restrictive clause "by DoD

intelligence components authorized under [E. 0. 123 3 31 ." In other words, by asserting

that OUSD(P) (admittedly not a "DoD intelligence component") engaged in "Intelligence

Activities," the Draft Report obviously regards those activities as something that can be

done by an entity that is not an "intelligence component." The Draft Report thus appears

to define "Intelligence Activities" as "the collection, production, and dissemination of

foreign intelligence and counterintelligence" simply, regardless of by whom or what.

(U) This re-definition not only is incorrect on its face but in practice would lead to

absurd results, as reference to the definition of "foreign intelligence" demonstrates. The

term "foreign intelligence" appears in the definition of "Intelligence Activities," i.e., the

"collection, production, and dissemination of foreign intelligence and counterintelligence

by DoD intelligence components authorized under" E.O. 12333. Both E.O. 12333

(Section 3.4(d)) and DoD Directive 5240.1 (Section 3.2) define "Foreign intelligence" as

"information relating to the capabilities, intentions and activities of foreign powers,

organizations or persons, but not including counterintelligence except for information on

international terrorist activities."

(U) This definition of "foreign intelligence" is quite broad. The New York Times,

for example, routinely engages in the collection (gathering and reporting), production

(writing and editing) and dissemination (publication) of information relating to the

"capabilities, intentions and activities of foreign powers, organizations or persons." In

the same vein, State Department Foreign Service officers, stationed both abroad and in

Washington, constantly, through their contacts with foreign officials and others, learn

about the "capabilities, intentions, and activities of foreign powers, organizations, or

persons"; they report this information, which is used by the regional and other bureaus of

the State Department to produce memoranda containing assessments and policy

recommendations, which, in turn, are disseminated to officials throughout the

government. Thus, if one were to accept the Draft Report's modification of the definition

of "intelligence activities," one would have to conclude that the New York Times and

State Department Foreign Service officers routinely engage in "intelligence activities."

(U) Similarly, OUSD(P) routinely deals with "information relating to the

capabilities, intentions, and activities of foreign powers, organizations, or persons." For

example:

(U) Policy personnel routinely meet with foreign counterparts, at both the leadership

and desk officer levels. These encounters occur at international meetings and

conferences, formal defense bi-lateral consultations, and formal or informal one-onone

meetings. During such meetings, policy personnel acquire "foreign intelligence"

information which is typically recorded in Memoranda for the Record, e-mails, etc.

(U) In addition, policy personnel seek out other sources of information about "the

capabilities, intentions, and activities of foreign powers, organizations, or persons,"

for example, by attending academic or other conferences, or by talking to

knowledgeable academics or other non-government experts on relevant subjects.

(U) On the basis of this information and other sources (including "open source"

intelligence, diplomatic reporting, as well as intelligence reports), Policy personnel

prepare memoranda containing their analyses of foreign situations and associated

policy recommendations. Almost all the work of regional offices, and much of the

work of functional offices, deals with "the capabilities, intentions, and activities of

foreign powers, organizations, or persons."

(U) These memoranda are disseminated within OUSD(P), to the Joint Staff and other

DoD components, to the Defense Department leadership and to interagency

colleagues.

(U) If this and similar activity were to be considered "Intelligence Activities," then

attempting to follow the Draft Report's recommendation that "internal controls" be

established to ensure that "Intelligence Activities" are not performed within OUSD(P)

would be tantamount to shutting down OUSD(P) altogether.

(U) In fact, the guidance and authorities discussed here and in the Draft Report

impose no restrictions on activities involving analyses, evaluations, assessments, critical

reviews, or even alternative judgments by non-IC offices, not even if the subject of such

analyses, etc. is intelligence reporting or intelligence products furnished by the IC, nor

even if such analyses, etc. lead to judgments about intelligence information furnished by

the IC that differ from the IC's judgments about the same information.

(U) Where the relevant guidance intends to prohibit or regulate activities by non-

IC offices, it does so in clear terms, and in only two instances: the prohibition on

engaging or conspiring to engage in assassination (E.O. 12333, Section 2.1 1 ; DoD

Directive No. 5240.1, Section 4.4); and the prohibition on all DoD Components from

conducting or providing support for the conduct of special activities except as the

Directive otherwise provides (DoD Directive No. 5240.1 Section 4.3). Other than these

two cases, the relevant guidance does not proscribe any activities by non-IC offices. In

particular it lacks any limitation on analyses or assessments by Policy offices of

Intelligence Community information and products. There is no basis for characterizing

the admittedly lawful and authorized work under review as "inappropriate."

VI. OUSD(P) NONCONCURRENCE (U)

A. With the Findings of the Draft Report (U)

(U) For all the reasons stated in these comments, OUSD(P) does not concur in any

finding expressed in the Draft Report except the finding that the activities reviewed were

lawful and authorized, and specifically does not concur in incorrect assertions (e.g., at

pages 4 and 14):

(U) That OUSD(P) "developed, produced and then disseminated alternative

intelligence assessments on the Iraq and al-Qaida relationship, which were

inconsistent with the consensus of the Intelligence Community, to senior decisionmakers";

(U) That the actions reviewed were allegedly "OUSD(P)" activities;

(U) That the actions reviewed were allegedly "inappropriate given that the products

did not clearly show the variance with the consensus of the Intelligence Community

and were, in some cases, shown as intelligence products";

(U) That there was an alleged "expanded role and mission of the OUSD(P) from

Defense Policy formulation to alternative intelligence analysis and dissemination";

(U) That anything inappropriate occurred because "OUSD(P) lacked the management

controls to ensure that Intelligence Activities were not performed, and that when

Policy disagreed with the Intelligence Community, products produced by Policy

clearly showed the variance with the Intelligence Community";

(U) That OUSD(P) had a responsibility to, but "did not provide 'the most accurate

analysis of intelligence' to senior decision-makers"; and

(U) That any OUSD(P) activities, in response to requests by the Deputy Secretary, the

Secretary of Defense or otherwise, constituted "Intelligence Activities."

B. With the Recommendations of the Draft Report (U)

(U) For all the reasons stated in these comments, OUSD(P) does not concur in any

recommendation expressed. in the Draft Report, and specifically does not concur in the

recommendations (page 14) that the Under Secretary of Defense for Policy:

"a. Establish internal controls so that 'Intelligence Activities' are not performed

within the Office of the Under Secretary of Defense for Policy" - as OUSD(P) did

not perform any "Intelligence Activities" and no such "internal controls" are

needed.

"b. If in its policy formulation role, there is disagreement with the Intelligence

Community consensus:

"(1 .) Use existing procedures within the Intelligence Community to request

an Alternative Judgment" - as existing IC prqcedures for producing

"alternative judgments" do not apply to non-IC offices and are irrelevant to

critiques by policy offices of IC work.

"(2.) Clearly articulate in policy products the Intelligence Community

consensus and the basis for disagreement or variance from the Intelligence

Community consensus" - as such a requirement would inappropriately

constrain policy work by requiring policy offices to vet every policy

product with the IC in order to determine whether or not it disagreed or

varied with an IC "consensus" and - if it did -- to articulate the IC

"consensus" in the policy product.

(U) Accordingly, OUSD(P) has taken no actions, and plans none, in response to

the proposed recommendations.

VII. CONCLUSION (U)

(U) Bipartisan reports and studies by various commissions and congressional

committees since the 911 1 attacks have stressed the need for hard questions and

alternative thinking on the part of the Intelligence and Policy Communities alike. The

motivation behind such observations has been a broadly held consensus that the

Intelligence Community suffered major failures in its assessments of several key threats

and issues before both the 911 1 attacks and the recent Iraq war. As the WMD

Commission wrote, to quote just one such report:

"We conclude that good-faith efforts by intelligence consumers to understand the

bases for analytic judgments . . . are entirely legitimate. This is the case even if

policymakers raise questions because they do not like the conclusions or are

seeking evidence to support policy preferences. Those who must use intelligence

are entitled to insist that they be fully informed as to both the evidence and the

analysis."53

(U) The conclusions in the Draft Report reflect a disturbing departure from the

trend in all these reports and studies to encourage the type of alternative thinking that

motivated the work reviewed in this Project. By mischaracterizing that work as

inappropriate "intelligence assessments," the Draft Report fundamentally misinterprets

what the work actually was - namely, a critical assessment by OSD, for policy purposes,

of IC reporting and finished IC products on contacts between Iraq and al-Qaida. Such

conclusions, if sustained, would have a dampening effect on future initiatives challenging

intelligence assessments. The facts do not justify such conclusions.

(U) The work found "inappropriate" was an exercise in alternative thinking that

the second most senior civilian in this Department directed his subordinates to prepare

and brief to the most senior official of this Department. The latter, after receiving the

draft briefing, directed that it be shared with the DCI. When the Deputy National

Security Advisor requested the briefing, the Deputy Secretary's office directed that it be

given to him. These are the activities that the Draft Report characterizes as

"inappropriate," because it considers them to be "production" and "dissemination" of an

"alternative intelligence assessment" contradicting assessments of the "charteredintelligence

community." If the OIG actually believes that it was inappropriate for the

Deputy Secretary of Defense to have some non-IC OSD staff members do a critical

assessment of some IC work on a subject of major significance for national security,

inappropriate for the Secretary of Defense to share the OSD work with the DCI, and

inappropriate for the Deputy Secretary to share the work with the Deputy National

Security Advisor when requested by the latter, the OIG should say so directly instead of

53 (U) Commission on the Intelligence Capabilities of the United States Regarding Weapons ofMass

Destruction, Report to the President of the United States (3 1 March 2005), p. 189.

finding fault with subordinate OSD offices and staff members who did as they were

instructed to do.

(U) The proposed recommendations would put a straightjacket on not only the

type of work reviewed here but also the large majority of work routinely done in OSD,

particularly in OUSD(P).

(U) By having OUSD(P) to articulate the Intelligence Community consensus in

any policy products that may vary from an IC "consensus" and the basis for such

variance, the proposed recommendations would inappropriately constrain policy

work. They would require policy offices to vet every policy recommendation or

analysis with the IC in order to determine whether or not it disagreed or varied

with an IC "consensus." The proposed recommendations would also burden

policy offices with a requirement to articulate the IC "consensus" when the IC

itself should do so.

(U) By having OUSD(P) to seek an "Alternative Judgment" from the IC whenever

any OUSD(P) product disagreed with IC views, the proposed recommendations

would seriously constrain and deter OUSD(P) personnel from articulating

alternative views about the same information on which the IC's assessments were

based.

(U) By mischaracterizing alternative reviews of IC work as "Intelligence

Activities," the conclusions of the Draft Report would chill the vigorous debate

and hard questioning that most observers have recognized as necessary to avoid

the types of intelligence failures experienced in the recent past.

(U) We strongly urge a reconsideration and major revision of the Draft Report and

the conclusions expressed therein.

Eric S. Edelman

Under Secretary of Defense for Policy


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