Index

Disaster medicine and the emergency medicine resident

Following recommendations made in Homeland Security Presidential Directive 7, which established a national policy for the identification and increased protection of critical infrastructure and key resources (CIKR) by Federal departments and agencies, the U.S. Department of Homeland Security (DHS) in 2006 developed the Enhanced Critical Infrastructure Protection (ECIP) program. The ECIP program aimed to provide a closer partnership with state, regional, territorial, local, and tribal authorities in fulfilling the national objective to improve CIKR protection. The program was specifically designed to identify protective measures currently in place in CIKR and to inform facility owners/operators of the benefits of new protective measures. The ECIP program also sought to enhance existing relationships between DHS and owners/operators of CIKR and to build relationships where none existed (DHS 2008; DHS 2009). In 2009, DHS and its protective security advisors (PSAs) began assessing CIKR assets using the ECIP program and ultimately produced individual protective measure and vulnerability values through the protective measure and vulnerability indices (PMI/VI). The PMI/VI assess the protective measures posture of individual facilities at their 'weakest link,' allowing for a detailed analysis of the most vulnerable aspects of the facilities (Schneier 2003), while maintaining the ability to produce an overall protective measures picture. The PMI has six main components (physical security, security management, security force, information sharing, protective measures assessments, and dependencies) and focuses on actions taken by a facility to prevent or deter the occurrence of an incident (Argonne National Laboratory 2009). As CIKR continue to be assessed using the PMI/VI and owners/operators better understand how they can prevent or deter incidents, academic research, practitioner emphasis, and public policy formation have increasingly focused on resilience as a necessary component of the risk management framework and infrastructure protection. This shift in focus toward resilience complements the analysis of protective measures by taking into account the three other phases of risk management: mitigation, response, and recovery (Figure 1). Thus, the addition of a robust resilience index (RI) to the established PMI/VI provides vital information to owners/operators throughout the risk management process. Combining a pre-incident focus with a better understanding of resilience, as well as potential consequences from damaged CIKR, allows owners/operators to better understand different ways to decrease risk by (1) increasing physical security measures to prevent an incident, (2) supplementing redundancy to mitigate the effects of an incident, and (3) enhancing emergency action and business continuity planning to increase the effectiveness of recovery procedures. Information provided by the RI methodology is also used by facility owners/operators to better understand how their facilities compare to similar sector/subsector sites and to help them make risk-based decisions. This report provides an overview of the RI methodology developed to estimate resilience and provide resilience comparisons for sectors and subsectors. The information will be used to (1) assist DHS in analyzing existing response and recovery methods and programs at facilities and (2) identify potential ways to increase resilience. The RI methodology is based on principles of Appreciative Inquiry, which is 'the coevolutionary search for the best in people, their organizations, and the relevant world around them' (Cooperrider et al. 2005). Appreciative Inquiry identifies the best of 'what is' and helps to envision 'what might be.' The ECIP program and the RI represent a new model (using Appreciative Inquiry principles) for information sharing between government and industry (Fisher and Petit 2010). A 'dashboard' display, which provides an interactive tool - rather than a static report, presents the results of the RI in a convenient format. Additional resilience measures can be modeled to illustrate how such actions would impact the asset's RI value.

The US Department of Homeland Security (DHS) has directed its Protective Security Advisors (PSAs) to form partnerships with the owners and operators of assets most essential to the Nation's well being - a subclass of critical infrastructure and key resources (CIKR) - and to conduct site visits for these and other high-risk assets as part of the Enhanced Critical Infrastructure Protection (ECIP) Program. During each such visit, the PSA documents information about the facility's current CIKR protection posture and overall security awareness. The primary goals for ECIP site visits (DHS 2009) are to: (1) inform facility owners and operators of the importance of their facilities as an identified high-priority CIKR and the need to be vigilant in light of the ever-present threat of terrorism; (2) identify protective measures currently in place at these facilities, provide comparisons of CIKR protection postures across like assets, and track the implementation of new protective measures; and (3) enhance existing relationships among facility owners and operators; DHS; and various Federal, State, local tribal, and territorial partners. PSAs conduct ECIP visits to assess overall site security; educate facility owners and operators about security; help owners and operators identify gaps and potential improvements; and promote communication and information sharing among facility owners and operators, DHS, State governments, and other security partners. Information collected during ECIP visits is used to develop metrics; conduct sector-by-sector and cross-sector vulnerability comparisons; identify security gaps and trends across CIKR sectors and subsectors; establish sector baseline security survey results; and track progress toward improving CIKR security through activities, programs, outreach, and training (Snyder 2009). The data being collected are used in a framework consistent with the National Infrastructure Protection Plan (NIPP) risk criteria (DHS 2009). The NIPP framework incorporates consequence, threat, and vulnerability components and addresses all hazards. The analysis of the vulnerability data needs to be reproducible, support risk analysis, and go beyond protection. It also needs to address important security/vulnerability topics, such as physical security, cyber security, systems analysis, and dependencies and interdependencies. This report provides an overview of the approach being developed to estimate vulnerability and provide vulnerability comparisons for sectors and subsectors. the information will be used to assist DHS in analyzing existing protective measures and vulnerability at facilities, to identify potential ways to reduce vulnerabilities, and to assist in preparing sector risk estimates. The owner/operator receives an analysis of the data collected for a specific asset, showing a comparison between the facility's protection posture/vulnerability index and those of DHS sector/subsector sites visited. This comparison gives the owner/operator an indication of the asset's security strengths and weaknesses that may be contributing factors to its vulnerability and protection posture. The information provided to the owner/operator shows how the asset compares to other similar assets within the asset's sector or subsector. A 'dashboard' display is used to illustrate the results in a convenient format. The dashboard allows the owner/operator to analyze the implementation of additional protective measures and to illustrate how such actions would impact the asset's Protective Measures Index (PMI) or Vulnerability Index (VI).

This study tested a hypothesized inverse correlation between the number of crisis intervention team (CIT) officers and the number of Special Weapons and Tactics (SWAT) callouts in an urban police department. Data for the number of accrued CIT-trained officers were combined with administrative data on the number of SWAT callouts during 27 four-month intervals. There were no significant correlations for the relationships examined, and implementation of CIT training was not associated with a decrease in SWAT callouts. Although the CIT model may yield important benefits in other domains, this study found no evidence of declining SWAT utilization as the number of CIT-trained officers accrued. The absence of association is likely due to the relatively low prevalence of SWAT use and the very different nature of CIT versus SWAT responses.

Since the 1990s, U.S. Customs and Border Protection (CBP) agents have killed approximately fifty Mexican and U.S. nationals along the U.S.-Mexico border. Many of the victims, including several teenagers, were unarmed and shot in the back. The vast majority of CBP agents have faced no criminal, civil, or disciplinary action for their conduct. This Article identifies U.S. legal doctrines, defenses, and procedures that make justice elusive for the relatives of victims. The Article argues that there is mounting legal and political pressure to hold CBP agents accountable for violence at the border and suggests that reformists look to international standards to help guide efforts to address systemic barriers to redress. To date, no civil plaintiff has prevailed at trial in a case involving a CBP killing. Courts have dismissed most federal civil claims for lack of jurisdiction or after finding the U.S. government or CBP agent has immunity. Federal legislation, specifically the Westfall Act, effectively bars state-law tort claims in this context. As for criminal charges, federal prosecutors have declined to bring charges in all cases but one and the few state prosecutions have rarely resulted in a guilty verdict. There is, however, mounting legal and political pressure to hold CBP agents accountable for border killings. In 2017, the U.S. Supreme Court is expected to decide whether the U.S. Constitution protects foreign nationals killed in foreign territory by CBP agents. The U.S. Department of Justice recently brought criminal charges against a CBP agent for a border killing for the first time in the CBP’s nearly 100-year history. The Mexican government is also investigating multiple deaths and issued an arrest warrant for a CBP agent who killed an unarmed Mexican teenager. In addition, international human rights bodies have denounced the United States for use of excessive force and the failure to track or adequately investigate border deaths. This Article discusses doctrines and defenses such as sovereign and qualified immunity, extraterritoriality, and the Westfall Act that have led to the dismissal of civil suits and the closing of criminal investigations without pursuing charges. But legal doctrines do not alone explain the lack of accountability—institutional policies and practices also play a critical role. This Article argues that international human rights standards reveal how far U.S. law enforcement has strayed from global standards in preventing the excessive use of force and serves as a guide to identify and address the systemic barriers to redress faced by victims’ families.

The Department of Homeland Security (DHS) has invested significant effort to assess whether cities and communities across the nation have the capabilities to respond effectively in the event of a potential chemical hazard release, terrorist attack, or natural disaster. The DHS strategy per Presidential Policy Directive 8: National Preparedness (PPD-8) is articulated in the National Preparedness Goal (2015) and efforts to achieve that goal require a capabilities-based planning approach. In an effort to assess these capabilities, Lawrence Livermore National Lab (LLNL) received funding from DHS to develop a Response Risk Assessment (RRA) process for potential chemical hazard events. The objective of the RRA process is to gather the essential information and data to evaluate limitations in overall response capabilities using rigorous quantitative analyses that focus on minimizing casualties. At the end of the process, a city or venue should be equipped with the actions it needs to take to meet capability standards articulated under the DHS national preparedness strategy. The RRA process uses the operational framework displayed in Figure ES-1 as a model to examine the emergency response system in detail, from initiation of an incident through definitive medical care. This operational framework is consistent with DHS/Federal Emergency Management Agency’s (FEMA) National Response Frameworks, particularly the core capabilities, Emergency Support Functions (ESF) (DHS, 2016) and National Incident Management System (NIMS)/Incident Command System (ICS) (DHS, 2017). The process framework is also consistent with the mission of the Department of Homeland Security Countering Weapons of Mass Destruction (CWMD) Office (DHS, 2018). Five municipalities across the nation worked with LLNL and DHS to implement demonstration projects that took place in partnership with local agencies, organizations, and other key stakeholders at the state and federal levels. Following the conclusion of the demonstration projects, LLNL prepared this document as a manual to guide users in implementing a Response Risk Assessment (RRA) for potential chemical hazard events. In addition to providing the background and foundation of the RRA approach, this document takes the reader through each part of the entire RRA process. Key timelines, meetings, and analysis actions are discussed and summarized in tables and figures. Critical information requirements to establish response timelines, assess population exposure, and consider capacity limitations that could increase casualties are presented in a manner that the RRA facilitator may employ to guide discussions with partners. Community partners may then establish actions for continual improvement in emergency response planning. To get facilitators off to a running start, examples of materials, tools, questionnaires, presentations, and templates used in an RRA are provided in the Attachments. They are encouraged to freely use and duplicate these materials. Finally, the document includes a summary of RRA enhancement areas and improvement opportunities identified by individuals, agencies, municipalities, and organizations involved in the demonstration projects. These nine enhancements are highlighted in Section 9.

After 9/11, the American intelligence community (IC) grew from few to uncountable, and the money allocated to the community could only be guessed at, given the secret and other funds that accompanied allocated funds for expanding intelligence capability. Out of this spiraling confusion, the Department of Homeland Security (DHS) was born to coordinate the disparate efforts of known and lesser-known intelligence organizations. However, the DHS could not handle the tremendous IC activity by himself, and by 2010, the Office of the Director of National Intelligence (ODNI), the Top Intelligence Officer in America was additionally established. Most of the work in bringing the IC together has been done by the DHS. It seems to have been successful in identifying the directions from which a threat may enter into the country. More importantly, the DHS has implemented a reporting system, together with reporting training, that will allow local law enforcement personnel to participate in the national security effort by logging their observations and disseminating them throughout the DHS system. That system is designed not just to collect information, but to share it with participating agencies (including local law enforcement) as well. Part of this initiative is the “See Something, Say Something” campaign that involves private citizens in the national security effort. Of all of the ODNI and DHS efforts, the private citizen observation campaign holds the most realistic promise and provides the best lesson for nations that would learn from the American terrorism response experience.

24 - Critical Infrastructures and Key Resources

The Importance of Trade Compliance Programs in Global Supply Chains The Global Supply Chain The Basics Steps of Structuring and Implementing Awareness Senior Management Analysis and Review Person(s) Responsible-Team Initiative Resource Development Action Plan Standard Operating Procedures (SOPs) Training and Education Self-Audit Global Contract Management INCO Terms of Sale/INCO Terms Payment Freight Title Revenue Recognition (Exports Only) Compliance Insurance: Loss and Damage Resources Outline Magazines Associations E-Mail Newsletters Export Logistics and Compliance Management Export Logistics, Freight Forwarding, and Shipping Export Freight Forwarding and Supply Chain Management Shipping Costs Shipping Cost Breakdown Value-Added Services Power of Attorney INCO Terms in Logistics Terms of Payment Export Packing Management Policy Set Packing Guidelines Packaging Resources Managing Compliance and Documentation Export Compliance Census Valuation Harmonized Tariff Schedule/Schedule B Number Bureau of Industry and Security (BIS) Export Control Classification Number (ECCN) Denied Party Screening Office of Foreign Asset Controls Export Documentation FCPA Awareness and Adherence Documentation and Letters of Credit Import Management and Inbound Logistics The Bureau of Customs and Border Protection (CBP) Profile The Department of Homeland Security (DHS) Organizational Structure Import Regulatory Issues Import Management: Importer of Record vs. Ultimate Consignee Reasonable Care Meeting Reasonable Care Standards Best Practices: Ten Steps to Achieve Import Compliance C-TPAT: Customs-Trade Partnership Against Terrorism Importer Self-Assessment (ISA) Program Quick Response Audits Global Security Awareness Container Security Initiative Advanced Manifest Notification Programs Wheels Up or Four-Hour Advanced Notification Two-Hour Advanced Notification for Ground and Rail Shipments Flexibility of Filing Postloading Filing Privileges Foreign Cargo Remaining On Board Implementation Process of Final Rule Methods of Filing ISF Data Valuation Verification Methods of Valuation Assists Royalties Commissions Customs Powers of Attorney Revocation Validating the Power of Attorney Certificate of Registration Foreign Shipper's Repair/Manufacturer's Affidavit Importation and Customs Clearance Process Record Keeping Recommendations of Compliance Methods of Storage of Records Customs Bonds Parties to a Bond Types of Bonds Amounts of Bonds Invoices Invoice Requirements Duty Drawback Harmonized Tariff System Format Techniques of Classification HTSUS Number Structure Government Agencies Controlling Supply Chain Issues Government Agencies Involved in Exporting Department of Commerce: Bureau of Industry and Security Department of Commerce: Office of Antiboycott Compliance Department of State: Directorate of Defense Trade Controls Department of Commerce: Bureau of Census,Foreign Trade Division Department of Justice: Drug Enforcement Administration, Office of Diversion Control (Chemicals and Controlled Substances) Department of Health and Human Services: Food and Drug Administration (Drugs and Biologics, Investigational Drugs Permitted, Medical Devices) Department of Energy: Natural Gas and Electric Power Department of Energy: Nuclear Regulatory Commission: Office of International Programs (Nuclear Materials and Equipment, Technical Data for Nuclear Weapons) Department of Homeland Security: Customs and Border Protection (CBP) Federal Maritime Commission: Ocean Freight Forwarders Department of Commerce: Patent and Trademark Office Department of Homeland Security: Transportation Security Administration Department of the Treasury: Office of Foreign Asset Controls Department of Interior: Fish and Wildlife Services Government Agencies Involved in Importing U.S. Customs and Border Protection Food and Drug Administration Department of Agriculture, Animal Plant Health Inspection Service Consumer Products Safety Commission U.S. Fish and Wildlife Service Federal Communications Commission Utilization of Technology Options Technology Advantages Service Providers and Technology RFID: Trade Compliance and Import-Export Management Personnel Deployment, Training, and Best Practices Where Should Trade Compliance Be Managed? Training and Education PACMAN Benefits U.S. Export Compliance.com: A Solution for U.S. Trade Compliance Education and Training Benchmarking and Best Practices Best Practices in Trade Compliance Organized and Formal Education and Training Putting Best Practices for Trade Compliance into an Action Plan Glossary Key Acronyms Key International Web Sites Appendices All About AES: The Automated Export System Supply Chain Security Best Practices Catalog Foreign Corrupt Practices Act Antibribery Provisions INCO Terms 2000 Sample Documentation for an Export and Import Shipment

By examining the influence of social, political, economic and cultural forces on the evolution of modern law enforcement, this updated Third Edition discusses the struggle between existing conventions in law enforcement and today's push for reform. This book is an ideal introduction to law enforcement and goes beyond discussions of local policing to examine how forces like technology, privatization, and the threat of terrorism are affecting law enforcement on local, state, and national levels. Readers will learn how these diverse and unpredictable forces are shaping the future of law enforcement in the United States, and will come away with the ability to think critically about law enforcement issues. New Material added to the revised and updated Third Edition: -Stay Current boxes throughout the text offer references and key search terms for further internet research -Updated figures, tables, charts and other statistical and descriptive information -A New chapter on socialization, advancement, and professionalism, including ethics and misconduct -A New chapter with emphasis on law enforcement's role in national security, homeland security, and protecting private assets -A separate chapter on Policing Strategies, Tactics, and Daily Operations -An expanded and updated chapter on management issues -Updated and expanded appendices

Critical Infrastructure and Key Resources (CIKR) models and simulations may be used to understand infrastructure systems, their interdependencies, their vulnerabilities, and the impact of the propagation of damage across interdependent infrastructure systems based upon emergency incidents.They may also be used to support training exercises, performance measurement, conceptual design, impact evaluation, response planning, analysis, acquisition, conceptualizing and evaluating new systems, vulnerability analysis, economic impact, and determining interdependencies between CIKR systems.The goal of this document is to capture the current knowledge and information resources that can serve as a common baseline for researchers and developers of models and simulations of CIKR for homeland security applications.This initial version of the document attempts to assemble relevant, publicly available information from a number of sources within U.S. Department of Homeland Security (DHS) and the modeling and simulation (M&S) communities.This document is intended to help initiate the discussion of the current leading research, development, standards, and implementation issues within the CIKR M&S community.The document will be updated based on the input of domain experts across government, research, and commercial organizations.These experts will be invited to join together in a workshop to review and extend this document for its final publication.The workshop will focus on simulation and modeling activities and needs that support analysis, planning, and training for the CIKR sectors as well as the integration of M&S applications across the sectors.Issues to be addressed within the scope of this workshop include the establishment of consensus on: redundancy between the documents, each document focuses on the M&S techniques that are most significant to the sectors mission and objectives.The CIKR document emphasizes modeling and simulation supporting analysis of systems (e.g., vulnerability, security), whereas the incident management document focuses more on training and exercises.The healthcare systems document addresses M&S for analysis, training, and exercises, but at a more detailed level than the previous two documents.The hazardous material release document focuses on the more physical aspects of M&S associated with explosions, fires, plumes, and the flow of hazardous materials in building ventilation systems, bodies of water, and the soil.The authors recognize that each of the sectors may employ all of the M&S techniques that have been identified in the other documents, but typically to a lesser extent.

Teaching critical infrastructure protection and resilience using exercises and WebEOC: An examination of UAE undergraduate students’ after-action reports

Argonne National Laboratory in partnership with the US Department of Homeland Security (DHS) has developed a methodology to systematically evaluate the protection posture and vulnerability of critical infrastructure and key resources (CIKR). This vulnerability methodology is part of a larger effort by DHS called the Enhanced Critical Infrastructure Protection Programme, which seeks to mitigate vulnerabilities, enhance relationships, and improve information sharing between public and private entities. This methodology was constructed to be used in all CIKR sectors and to provide useful results to owners and operators of US facilities. The vulnerability index is also being used to assist DHS in analysing sector and subsector vulnerabilities, to identify potential ways to reduce vulnerabilities, and to assist in preparing sector risk estimates. The owner/operator also receives an analysis of the data collected for a specific asset, which gives an indication of the asset’s strengths and weaknesses with regard to security.

Purpose The change in Thailand to a super-aged society means that elder protection has become a national priority. Although elder abuse is reported to the police and law enforcement is usually the first responder, they are not trained in protecting older people, particularly in cases of emotional abuse and economic exploitation. This study aims to present the prevalence of elder abuse in urban Thailand and examine the role, perception and limitations of law enforcement in elder protection. Design/methodology/approach The authors used a sequential, explanatory, mixed-methods design to collect survey data, specifically with 500 older adults, stratified randomly. Face-to-face surveys explored elder abuse, legal knowledge and awareness, and perceptions of police involvement in elder protection. Qualitative data were obtained through 20 key informant interviews (police, social workers, medical personnel and legal professionals). Quantitative data analysis included t-tests, ANOVA and regression; qualitative knowledge was thematically coded. Findings The form of elder abuse most commonly observed by older adults was emotional (44.2%) and economic (39.8%); rates were higher for emotional and economic abuse among female older adults and those with lower education. The best predictor of how older adults viewed police effectiveness was the level of education, legal knowledge, and previous engagement with police. The qualitative findings revealed challenges related to legal ambiguity, poor inter-agency coordination, and officer burnout. Cultural restrictions on families with elder abuse and the privatization of family violence were also issues to address. Research limitations/implications The study focused solely on urban contexts located in Bangkok; therefore, it may not consider rural or minority ethnospecific experiences. While this limits representational validity, sampling of key informants in this study created a selection bias across institutional perspectives. Although limitations impacted the representational validity of the general findings, the mixed-methods approach permitted strong data triangulation to imply, point to recommendations and generate future work with action. Future studies should concern rural–urban disparity, longitudinal movements in elder abuse and comparisons as to how law enforcement protections vulnerable elderly individuals in the local or international contexts. Practical implications The importance of implementing integrated Elder Protection Units within the Royal Thai Police, standardized inter-agency referral protocols in elder protection cases and training in elder rights and trauma-informed policing can effectuate real change in elder protection. The call for policy reform based on systemic gaps in public legal education, community awareness of empowering older persons through volunteers, is an actionable strategy with immediate implications to boost elder protection in Thailand and improve the consideration of older individuals’ dignity and rights through their engagement with social justice. Social implications Elder abuse identified within social structures by culture and silence is difficult to amend in Thailand. This research indicated that systemic deficits in policing, social protection and factors beyond themselves impacted individual factors in reporting elder abuse or neglect, endorsed normalization through silent family structures and spell blindness through the lack of responses by police as a symptom of systemic failures. Framing elder abuse as human rights concerns instead of individual ones promotes reformulation of police responder roles and behavior, catalyses engagement of community in the matter and promotes protection of elder persons' rights and dignity toward aging respectfully together. Originality/value This research is one of the few studies in Thailand to use amixed-methods design to investigate elder abuse and the role of law enforcement. The topic of this study focuses on a seldom discussed venue of the police as operational and perception lenses in how to contribute to restoring elder protection and protection in an aging society. The theoretical framework draws from social ecology, routine activity theories, victimology and costs that create nodes between criminology points of view and social welfare policy. The evidence draws on local and global lessons learned in monitoring and creating actionable recommendations with a reorganization of the role of police in elder protection matters contributing globally to the conversation of aging rights, and policing in the Asian region.

U nlocking Human Dignity: A Plan to Transform the US Immigrant Detention System addresses one of the most troubled features of the US immigration system and highlights the need for fundamental changes to it. The report comes six years since the inception of the Obama administration’s detention reform initiative. In the interim, the number of immigrant detainees per year has risen to more than 400,000, the administration has opened immense new family detention centers, and the overwhelming majority of persons in the custody of the Department of Homeland Security (DHS) have remained in prisons, jails and other secure facilities where they are subject to standards designed for criminal defendants and, in many ways, treated more harshly than criminals. The report’s overarching recommendation is that the US immigrant detention system be dismantled and replaced with a network of supervised release, case management, and community support programs, designed to ensure court appearances. It recognizes that detention may be necessary for short periods and in certain cases, but it rejects detention as a central immigrant “management” tool, and argues that detention should only be used as a last resort if less harmful strategies and programs—viewed on a continuum beginning with the least restrictive and moving to release programs with different levels of supervision, monitoring, and support—cannot reasonably ensure court appearances or (in rare cases) protect the public. It opposes the detention of pregnant and nursing women, bona fide asylum seekers, the very ill, the disabled, the elderly, and other vulnerable persons. It calls for the substantial contraction of detention facilities and “bed space.” As the first step in this process, the report urges Congress to commission a comprehensive study on the benefits, challenges, cost, and time frame for creating a civil immigration detention system. It also proposes that the administration create a full menu of court compliance programs, with varying degrees of supervision, reporting, oversight and monitoring. In order to realize this vision, it offers several additional recommendations. T he Obama administration should desist from using detention as a “deterrent” to illegal migration and de facto refugee flows . DHS should close its family detention centers in favor of community-based supervision and support programs for immigrant families. The vast majority of families would appear for removal proceedings with appropriate orientation, supervision and community support. The growth of an immense family detention infrastructure will not (as intended) deter imperiled persons from seeking refuge in the United States, but will invariably lead to the return of de facto refugees to their persecutors in violation of international law. C ongress should pass legislation to repeal mandatory detention in all but the most egregious criminal and national security cases . US mandatory detention laws cover lawful permanent residents, asylum seekers, petty offenders, and persons with US families and other enduring ties to the United States. By definition, they prevent individualized release determinations based on family ties, employment, housing, criminal history, and other factors. In the overwhelming majority of cases, immigration judges or judicial officers should be permitted to consider the full range of equities and release options for persons in removal proceedings, whether formal court proceedings or non-court, administrative and summary processes. P r ivate corporations should have a more limited, regulated and modest role in a shrinking detention system . The federal government has increasingly ceded responsibility for detention to entities whose loyalties run to their shareholders, not the common good. By some estimates, for-profit prison corporations administer more than 60 percent of the “beds” in the US immigrant detention system. Rather than expanding its reliance on for-profit prison companies, the federal government ought to decrease the use of detention, develop greater government expertise, and strengthen oversight of private contractors. D etention reform should include a significant expansion of Alternative to Detention programs (ATD) . Detention should only be used sparingly, for brief periods (when necessary), and as a last resort when less restrictive strategies cannot reasonably ensure appearances during the adjudication and removal process and cannot protect the public. ATD programs can offer effective, humane alternatives to detention. However, they should not be used to expand detention capacity. Like detention, intensive reporting and monitoring programs can stigmatize and incapacitate persons. If necessary, ATD programs should be treated as a form of custody, which would open them to mandatory detainees. Immigration and Customs Enforcement (ICE) should undertake a comprehensive analysis of its information systems . The proposed review should identify the information ICE tracks on those who are subject to its custody; how, when, and which officials collect, enter, and can access this information; its quality control procedures; and the accessibility of information to congressional oversight committees, government watchdog agencies, relevant ICE officials, and the public. D etained immigrants—those who do not qualify for release or ATD programs—should be held in non-penal settings which reflect the conditions of normal life to the extent feasible . DHS should provide generous access to international organizations, faith-based groups, nongovernmental organizations (NGOs) and the press, to all of its facilities. Immigration judges should adjudicate removal cases now handled through administrative, informal and non-court processes, and should make release and custody determinations soon after their detention for all persons in DHS custody . They should also regularly revisit custody decisions for detainees. However, these responsibilities—added to an immense yearly workload and a daunting backlog of more than 440,000 cases—will require increases in funding and staffing by an order of magnitude. As it stands, the immigration court system receives less than two percent of the combined funding of Customs and Border Protection (CBP) and ICE. The cost of “right-sizing” the immigration court system may well be offset by reductions in DHS detention funding and diminished federal court expenses from habeas corpus petitions. U nrepresented, indigent persons in removal proceedings should be provided with legal representation at the government’s expense . As numerous studies have revealed, legal counsel is one of the most important factors, even more important than the strength of the underlying legal claim, in influencing asylum and other case outcomes. Representation also increases court appearance rates and leads to decreased overall costs to the government due to reduced use of detention, more efficient court proceedings, and less frequent placement of the children of detainees in foster care. More importantly, it contributes to the right decisions being made under the law. Migration and Refugee Services of the US Conference of Catholic Bishops (MRS/USCCB) and the Center for Migration Studies (CMS) approach the detention of immigrants from a pastoral perspective. Each day US Catholic institutions minister to detained immigrants, represent them in removal proceedings, tend to the material and spiritual needs of their families, and witness the pain of traumatized children and the anguish of divided families. Because of the detention system’s devastating effect on the lives of millions of persons each year, MRS/USCCB and CMS strongly support the transformation of this system and urge the Obama administration and Congress to proceed with the proposed reforms with all deliberate haste.