[House Report 115-603]
[From the U.S. Government Publishing Office]
115th Congress } { Report
HOUSE OF REPRESENTATIVES
2d Session } { 115-603
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ENHANCING DHS' FUSION CENTER TECHNICAL ASSISTANCE PROGRAM ACT
_______
March 19, 2018.--Committed to the Committee of the Whole House on the
State of the Union and ordered to be printed
_______
Mr. McCaul, from the Committee on Homeland Security, submitted the
following
R E P O R T
[To accompany H.R. 5099]
The Committee on Homeland Security, to whom was referred
the bill (H.R. 5099) to amend the Homeland Security Act of 2002
to establish in the Department of Homeland Security a fusion
center technical assistance program, having considered the
same, report favorably thereon without amendment and recommend
that the bill do pass.
CONTENTS
Page
Purpose and Summary.............................................. 2
Background and Need for Legislation.............................. 2
Hearings......................................................... 3
Committee Consideration.......................................... 3
Committee Votes.................................................. 3
Committee Oversight Findings..................................... 3
New Budget Authority, Entitlement Authority, and Tax Expenditures 3
Congressional Budget Office Estimate............................. 3
Statement of General Performance Goals and Objectives............ 4
Duplicative Federal Programs..................................... 4
Congressional Earmarks, Limited Tax Benefits, and Limited Tariff
Benefits....................................................... 4
Federal Mandates Statement....................................... 4
Preemption Clarification......................................... 4
Disclosure of Directed Rule Makings.............................. 4
Advisory Committee Statement..................................... 4
Applicability to Legislative Branch.............................. 5
Section-by-Section Analysis of the Legislation................... 5
Changes in Existing Law Made by the Bill, as Reported............ 6
Purpose and Summary
The Enhancing DHS' Fusion Center Technical Assistance
Program Act authorizes and enhances the Department of Homeland
Security's fusion center technical assistance program. The
program is required to focus on providing the 79 fusion centers
across the United States with technical assistance regarding
intelligence and information sharing, terrorism prevention
activities and the State Homeland Security Grant Program and
the Urban Area Security Initiative grant program.
Background and Need for Legislation
In November 2017, the Committee on Homeland Security
Majority Staff released a report entitled ``Advancing the
Homeland Security Information Sharing Environment: A Review of
the National Network of Fusion Centers.'' The report included a
review of the existing fusion center technical assistance
program in the Department of Homeland Security (DHS) and
recommended that the Office of Intelligence and Analysis (I&A)
and the Federal Emergency Management Agency (FEMA) ``enhance
the support available to fusion centers from FEMA's Technical
Assistance Program and address the need for more direct I&A
connectivity with the program.''\1\
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\1\The United States House of Representatives Committee on Homeland
Security, Advancing the Homeland Security Information Sharing
Environment: A Review of the National Network of Fusion Centers, at 12,
November 2017. https://homeland.house.gov/wp-content/uploads/2017/11/
Committee-on-Homeland-Security-Fusion-Center-Report.pdf
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In 2009, despite I&A being the primary DHS agency that
interacts with fusion centers, FEMA was given the
responsibility for the Department's fusion center technical
assistance program. It is the Committee's understanding that
the decision to place FEMA in charge of the technical
assistance program was largely based on available resources.
The current fusion center technical program largely provides
training for fusion center personnel on a range of topics,
including suspicious activity reporting, new director on-
boarding, and critical infrastructure and key resources.
The Committee noted in the November 2017 report widespread
concerns within the fusion center community that the quality
and available resources from current technical assistance
program had diminished.\2\ Additionally, the Committee found
that I&A does not have active engagement with the program.
---------------------------------------------------------------------------
\2\The United States House of Representatives Committee on Homeland
Security, Advancing the Homeland Security Information Sharing
Environment: A Review of the National Network of Fusion Centers, at 11-
12, November 2017.
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The bill seeks to address these shortfalls by providing
statutory authorization for the program, allowing the Secretary
the flexibility to maintain the program at FEMA or transfer it
elsewhere in the Department if deemed appropriate, and
expanding the mission of the existing office to include
technical assistance in other key areas. These include
information and guidance regarding homeland security grants,
terrorism prevention activities across DHS, and information
sharing activities. The latter two activities will result in a
more direct role in the program by I&A. Additionally, the bill
requires the program to be a repository for best practices
relevant to fusion centers.
Hearings
The Committee did not hold any hearing specifically on H.R.
5099, but the Subcommittee on Counterterrorism and Intelligence
held several hearings relevant to the bill.
On February 26, 2015, the Subcommittee on Counterterrorism
and Intelligence held a hearing entitled ``Addressing Remaining
Gap in Federal, State, and Local Information Sharing.'' The
Subcommittee received testimony from Mr. Mike Sena, President,
National Fusion Center Association; Chief Richard Beary,
President, International Association of Chiefs of Police; and
Dr. Cedric Alexander, National President, National Organization
of Black Law Enforcement Executives.
On September 8, 2016, the Subcommittee on Counterterrorism
and Intelligence held a hearing entitled ``State and Local
Perspectives on Federal Information Sharing.'' The Subcommittee
received testimony from Mr. Mike Sena, President, National
Fusion Center Association; Chief Richard Beary, Immediate Past
President, International Association of Chiefs of Police; and
Dr. Cedric Alexander, National President, National Organization
of Black Law Enforcement Executives.
Committee Consideration
The Committee met on March 7, 2018, to consider H.R. 5099,
and ordered the measure to be reported to the House with a
favorable recommendation, without amendment, by unanimous
consent.
Committee Votes
Clause 3(b) of Rule XIII of the Rules of the House of
Representatives requires the Committee to list the recorded
votes on the motion to report legislation and amendments
thereto.
No recorded votes were requested during consideration of
H.R. 5099.
Committee Oversight Findings
Pursuant to clause 3(c)(1) of Rule XIII of the Rules of the
House of Representatives, the Committee has held oversight
hearings and made findings that are reflected in this report.
New Budget Authority, Entitlement Authority, and Tax Expenditures
In compliance with clause 3(c)(2) of Rule XIII of the Rules
of the House of Representatives, the Committee finds that H.R.
5099, the Enhancing DHS' Fusion Center Technical Assistance
Program Act, would result in no new or increased budget
authority, entitlement authority, or tax expenditures or
revenues.
Congressional Budget Office Estimate
Pursuant to clause 3(c)(3) of Rule XIII of the Rules of the
House of Representatives, a cost estimate provided by the
Congressional Budget Office pursuant to section 402 of the
Congressional Budget Act of 1974 was not made available to the
Committee in time for the filing of this report. The Chairman
of the Committee shall cause such estimate to be printed in the
Congressional Record upon its receipt by the Committee.
Statement of General Performance Goals and Objectives
Pursuant to clause 3(c)(4) of Rule XIII of the Rules of the
House of Representatives, H.R. 5099 contains the following
general performance goals and objectives, including outcome
related goals and objectives authorized.
The goal of H.R. 5099 is to address the shortfalls of the
Department's current fusion center technical assistance program
by providing statutory authorization for the program, allowing
the Secretary the flexibility to maintain the program at FEMA
or transfer it elsewhere in the Department if deemed
appropriate, and expanding the mission of the existing office
to include technical assistance in other key areas.
Duplicative Federal Programs
Pursuant to clause 3(c) of Rule XIII, the Committee finds
that H.R. 5099 does not contain any provision that establishes
or reauthorizes a program known to be duplicative of another
Federal program.
Congressional Earmarks, Limited Tax Benefits, and Limited Tariff
Benefits
In compliance with Rule XXI of the Rules of the House of
Representatives, this bill, as reported, contains no
congressional earmarks, limited tax benefits, or limited tariff
benefits as defined in clause 9(e), 9(f), or 9(g) of the Rule
XXI.
Federal Mandates Statement
An estimate of Federal mandates prepared by the Director of
the Congressional Budget Office pursuant to section 423 of the
Unfunded Mandates Reform Act was not made available to the
Committee in time for the filing of this report. The Chairman
of the Committee shall cause such estimate to be printed in the
Congressional Record upon its receipt by the Committee.
Preemption Clarification
In compliance with section 423 of the Congressional Budget
Act of 1974, requiring the report of any Committee on a bill or
joint resolution to include a statement on the extent to which
the bill or joint resolution is intended to preempt State,
local, or Tribal law, the Committee finds that H.R. 5099 does
not preempt any State, local, or Tribal law.
Disclosure of Directed Rule Makings
The Committee estimates that H.R. 5099 would require no
directed rule makings.
Advisory Committee Statement
No advisory committees within the meaning of section 5(b)
of the Federal Advisory Committee Act were created by this
legislation.
Applicability to Legislative Branch
The Committee finds that the legislation does not relate to
the terms and conditions of employment or access to public
services or accommodations within the meaning of section
102(b)(3) of the Congressional Accountability Act.
Section-by-Section Analysis of the Legislation
Section 1. Short Title.
This section provides that this bill may be cited as the
``Enhancing DHS' Fusion Center Technical Assistance Program
Act''.
Sec. 2. Fusion Center Technical Assistance Program.
The section amends section 210A of the Homeland Security
Act of 2002 by adding a requirement that the Secretary of
Homeland Security establish a fusion center technical
assistance program at the Department. In establishing the
program, the Secretary is required to consult with the National
Network of Fusion Centers and other relevant stakeholders.
During the Committee's review of the National Network of Fusion
Centers, staff heard about the widespread concerns with the
Department's current fusion center technical assistance
program. Even more troubling, Committee staff heard that I&A,
DHS' primary point of contact for fusion centers, is not
actively engage with the current program. This section will
result in I&A having a more direct role in the program.
Additionally, the section lays out the specific
requirements the technical assistance program must address.
These include providing technical assistance regarding
intelligence and information sharing and terrorism prevention
activities, including training. The Committee's November 2017
fusion center report mentioned there is a communication
breakdown between fusion centers, FEMA's Grants Programs
Directorate, and I&A regarding fusion centers use of the State
Homeland Security Grants and Urban Area Security Initiative.
While it is unclear what has caused this breakdown, this
section addresses the issue by requiring this program to
provide technical assistance on the grant programs.
Lastly, the Committee's report highlighted establishment of
the National Network Center of Best Practice. The National
Network of Fusion Centers took the initiative and developed a
repository like place for best practices on the Homeland
Security Information Network--Intel.\3\ The National Network
Center of Best Practices is still in its infancy and the true
impact of this repository is still unknown. This section will
build on this initiative by ensuring Department's fusion center
technical assistance program also make available best practices
on operations, sharing and analysis of homeland security
threats, and protecting civil liberty, civil rights, and
privacy to the 79 fusion centers.
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\3\The Homeland Security Information Network--Intelligence is a
trusted and secure network for Federal, State, local, territorial,
tribal partners to share sensitive but unclassified information. The
program is operated by the Department of Homeland Security and fusion
centers, as well as other vetted stakeholders, are provided access.
Changes in Existing Law Made by the Bill, as Reported
In compliance with clause 3(e) of rule XIII of the Rules of
the House of Representatives, changes in existing law made by
the bill, as reported, are shown as follows (existing law
proposed to be omitted is enclosed in black brackets, new
matter is printed in italic, and existing law in which no
change is proposed is shown in roman):
HOMELAND SECURITY ACT OF 2002
* * * * * * *
TITLE II--INFORMATION ANALYSIS AND INFRASTRUCTURE PROTECTION
Subtitle A--Information and Analysis and Infrastructure Protection;
Access to Information
* * * * * * *
SEC. 210A. DEPARTMENT OF HOMELAND SECURITY STATE, LOCAL, AND REGIONAL
FUSION CENTER INITIATIVE.
(a) Establishment.--The Secretary, in consultation with the
program manager of the information sharing environment
established under section 1016 of the Intelligence Reform and
Terrorism Prevention Act of 2004 (6 U.S.C. 485), the Attorney
General, the Privacy Officer of the Department, the Officer for
Civil Rights and Civil Liberties of the Department, and the
Privacy and Civil Liberties Oversight Board established under
section 1061 of the Intelligence Reform and Terrorism
Prevention Act of 2004 (5 U.S.C. 601 note), shall establish a
Department of Homeland Security State, Local, and Regional
Fusion Center Initiative to establish partnerships with State,
local, and regional fusion centers.
(b) Department Support and Coordination.--Through the
Department of Homeland Security State, Local, and Regional
Fusion Center Initiative, and in coordination with the
principal officials of participating State, local, or regional
fusion centers and the officers designated as the Homeland
Security Advisors of the States, the Secretary shall--
(1) provide operational and intelligence advice and
assistance to State, local, and regional fusion
centers;
(2) support efforts to include State, local, and
regional fusion centers into efforts to establish an
information sharing environment;
(3) conduct tabletop and live training exercises to
regularly assess the capability of individual and
regional networks of State, local, and regional fusion
centers to integrate the efforts of such networks with
the efforts of the Department;
(4) coordinate with other relevant Federal entities
engaged in homeland security-related activities;
(5) provide analytic and reporting advice and
assistance to State, local, and regional fusion
centers;
(6) review information within the scope of the
information sharing environment, including homeland
security information, terrorism information, and
weapons of mass destruction information, that is
gathered by State, local, and regional fusion centers,
and to incorporate such information, as appropriate,
into the Department's own such information;
(7) provide management assistance to State, local,
and regional fusion centers;
(8) serve as a point of contact to ensure the
dissemination of information within the scope of the
information sharing environment, including homeland
security information, terrorism information, and
weapons of mass destruction information;
(9) facilitate close communication and coordination
between State, local, and regional fusion centers and
the Department;
(10) provide State, local, and regional fusion
centers with expertise on Department resources and
operations;
(11) provide training to State, local, and regional
fusion centers and encourage such fusion centers to
participate in terrorism threat-related exercises
conducted by the Department; and
(12) carry out such other duties as the Secretary
determines are appropriate.
(c) Personnel Assignment.--
(1) In general.--The Under Secretary for Intelligence
and Analysis shall, to the maximum extent practicable,
assign officers and intelligence analysts from
components of the Department to participating State,
local, and regional fusion centers.
(2) Personnel sources.--Officers and intelligence
analysts assigned to participating fusion centers under
this subsection may be assigned from the following
Department components, in coordination with the
respective component head and in consultation with the
principal officials of participating fusion centers:
(A) Office of Intelligence and Analysis.
(B) Office of Infrastructure Protection.
(C) Transportation Security Administration.
(D) United States Customs and Border
Protection.
(E) United States Immigration and Customs
Enforcement.
(F) United States Coast Guard.
(G) Other components of the Department, as
determined by the Secretary.
(3) Qualifying criteria.--
(A) In general.--The Secretary shall develop
qualifying criteria for a fusion center to
participate in the assigning of Department
officers or intelligence analysts under this
section.
(B) Criteria.--Any criteria developed under
subparagraph (A) may include--
(i) whether the fusion center,
through its mission and governance
structure, focuses on a broad
counterterrorism approach, and whether
that broad approach is pervasive
through all levels of the organization;
(ii) whether the fusion center has
sufficient numbers of adequately
trained personnel to support a broad
counterterrorism mission;
(iii) whether the fusion center has--
(I) access to relevant law
enforcement, emergency
response, private sector, open
source, and national security
data; and
(II) the ability to share and
analytically utilize that data
for lawful purposes;
(iv) whether the fusion center is
adequately funded by the State, local,
or regional government to support its
counterterrorism mission; and
(v) the relevancy of the mission of
the fusion center to the particular
source component of Department officers
or intelligence analysts.
(4) Prerequisite.--
(A) Intelligence analysis, privacy, and civil
liberties training.--Before being assigned to a
fusion center under this section, an officer or
intelligence analyst shall undergo--
(i) appropriate intelligence analysis
or information sharing training using
an intelligence-led policing curriculum
that is consistent with--
(I) standard training and
education programs offered to
Department law enforcement and
intelligence personnel; and
(II) the Criminal
Intelligence Systems Operating
Policies under part 23 of title
28, Code of Federal Regulations
(or any corresponding similar
rule or regulation);
(ii) appropriate privacy and civil
liberties training that is developed,
supported, or sponsored by the Privacy
Officer appointed under section 222 and
the Officer for Civil Rights and Civil
Liberties of the Department, in
consultation with the Privacy and Civil
Liberties Oversight Board established
under section 1061 of the Intelligence
Reform and Terrorism Prevention Act of
2004 (5 U.S.C. 601 note); and
(iii) such other training prescribed
by the Under Secretary for Intelligence
and Analysis.
(B) Prior work experience in area.--In
determining the eligibility of an officer or
intelligence analyst to be assigned to a fusion
center under this section, the Under Secretary
for Intelligence and Analysis shall consider
the familiarity of the officer or intelligence
analyst with the State, locality, or region, as
determined by such factors as whether the
officer or intelligence analyst--
(i) has been previously assigned in
the geographic area; or
(ii) has previously worked with
intelligence officials or law
enforcement or other emergency response
providers from that State, locality, or
region.
(5) Expedited security clearance processing.--The
Under Secretary for Intelligence and Analysis--
(A) shall ensure that each officer or
intelligence analyst assigned to a fusion
center under this section has the appropriate
security clearance to contribute effectively to
the mission of the fusion center; and
(B) may request that security clearance
processing be expedited for each such officer
or intelligence analyst and may use available
funds for such purpose.
(6) Further qualifications.--Each officer or
intelligence analyst assigned to a fusion center under
this section shall satisfy any other qualifications the
Under Secretary for Intelligence and Analysis may
prescribe.
(d) Responsibilities.--An officer or intelligence analyst
assigned to a fusion center under this section shall--
(1) assist law enforcement agencies and other
emergency response providers of State, local, and
tribal governments and fusion center personnel in using
information within the scope of the information sharing
environment, including homeland security information,
terrorism information, and weapons of mass destruction
information, to develop a comprehensive and accurate
threat picture;
(2) review homeland security-relevant information
from law enforcement agencies and other emergency
response providers of State, local, and tribal
government;
(3) create intelligence and other information
products derived from such information and other
homeland security-relevant information provided by the
Department; and
(4) assist in the dissemination of such products, as
coordinated by the Under Secretary for Intelligence and
Analysis, to law enforcement agencies and other
emergency response providers of State, local, and
tribal government, other fusion centers, and
appropriate Federal agencies.
(e) Border Intelligence Priority.--
(1) In general.--The Secretary shall make it a
priority to assign officers and intelligence analysts
under this section from United States Customs and
Border Protection, United States Immigration and
Customs Enforcement, and the Coast Guard to
participating State, local, and regional fusion centers
located in jurisdictions along land or maritime borders
of the United States in order to enhance the integrity
of and security at such borders by helping Federal,
State, local, and tribal law enforcement authorities to
identify, investigate, and otherwise interdict persons,
weapons, and related contraband that pose a threat to
homeland security.
(2) Border intelligence products.--When performing
the responsibilities described in subsection (d),
officers and intelligence analysts assigned to
participating State, local, and regional fusion centers
under this section shall have, as a primary
responsibility, the creation of border intelligence
products that--
(A) assist State, local, and tribal law
enforcement agencies in deploying their
resources most efficiently to help detect and
interdict terrorists, weapons of mass
destruction, and related contraband at land or
maritime borders of the United States;
(B) promote more consistent and timely
sharing of border security-relevant information
among jurisdictions along land or maritime
borders of the United States; and
(C) enhance the Department's situational
awareness of the threat of acts of terrorism at
or involving the land or maritime borders of
the United States.
(f) Database Access.--In order to fulfill the objectives
described under subsection (d), each officer or intelligence
analyst assigned to a fusion center under this section shall
have appropriate access to all relevant Federal databases and
information systems, consistent with any policies, guidelines,
procedures, instructions, or standards established by the
President or, as appropriate, the program manager of the
information sharing environment for the implementation and
management of that environment.
(g) Consumer Feedback.--
(1) In general.--The Secretary shall create a
voluntary mechanism for any State, local, or tribal law
enforcement officer or other emergency response
provider who is a consumer of the intelligence or other
information products referred to in subsection (d) to
provide feedback to the Department on the quality and
utility of such intelligence products.
(2) Report.--Not later than one year after the date
of the enactment of the Implementing Recommendations of
the 9/11 Commission Act of 2007, and annually
thereafter, the Secretary shall submit to the Committee
on Homeland Security and Governmental Affairs of the
Senate and the Committee on Homeland Security of the
House of Representatives a report that includes a
description of the consumer feedback obtained under
paragraph (1) and, if applicable, how the Department
has adjusted its production of intelligence products in
response to that consumer feedback.
(h) Rule of Construction.--
(1) In general.--The authorities granted under this
section shall supplement the authorities granted under
section 201(d) and nothing in this section shall be
construed to abrogate the authorities granted under
section 201(d).
(2) Participation.--Nothing in this section shall be
construed to require a State, local, or regional
government or entity to accept the assignment of
officers or intelligence analysts of the Department
into the fusion center of that State, locality, or
region.
(i) Guidelines.--The Secretary, in consultation with the
Attorney General, shall establish guidelines for fusion centers
created and operated by State and local governments, to include
standards that any such fusion center shall--
(1) collaboratively develop a mission statement,
identify expectations and goals, measure performance,
and determine effectiveness for that fusion center;
(2) create a representative governance structure that
includes law enforcement officers and other emergency
response providers and, as appropriate, the private
sector;
(3) create a collaborative environment for the
sharing of intelligence and information among Federal,
State, local, and tribal government agencies (including
law enforcement officers and other emergency response
providers), the private sector, and the public,
consistent with any policies, guidelines, procedures,
instructions, or standards established by the President
or, as appropriate, the program manager of the
information sharing environment;
(4) leverage the databases, systems, and networks
available from public and private sector entities, in
accordance with all applicable laws, to maximize
information sharing;
(5) develop, publish, and adhere to a privacy and
civil liberties policy consistent with Federal, State,
and local law;
(6) provide, in coordination with the Privacy Officer
of the Department and the Officer for Civil Rights and
Civil Liberties of the Department, appropriate privacy
and civil liberties training for all State, local,
tribal, and private sector representatives at the
fusion center;
(7) ensure appropriate security measures are in place
for the facility, data, and personnel;
(8) select and train personnel based on the needs,
mission, goals, and functions of that fusion center;
(9) offer a variety of intelligence and information
services and products to recipients of fusion center
intelligence and information; and
(10) incorporate law enforcement officers, other
emergency response providers, and, as appropriate, the
private sector, into all relevant phases of the
intelligence and fusion process, consistent with the
mission statement developed under paragraph (1), either
through full time representatives or liaison
relationships with the fusion center to enable the
receipt and sharing of information and intelligence.
(j) Fusion Center Technical Assistance Program.--
(1) Establishment.--The Secretary, in consultation
with officials from the National Network of Fusion
Centers and, to the greatest extent practicable, other
relevant stakeholders, shall establish a fusion center
technical assistance program.
(2) Elements of program.--In carrying out the fusion
center technical assistance program established under
paragraph (1), the Secretary shall--
(A) provide technical assistance to fusion
centers regarding--
(i) grants administered under
sections 2003 and 2004;
(ii) terrorism prevention activities;
and
(iii) intelligence and information
sharing;
(B) provide to fusion centers notice of any
changes to the activities referred to in
subparagraph (A);
(C) make available best practices regarding--
(i) fusion center operations;
(ii) information sharing and analysis
of homeland security threats, including
cyber threats;
(iii) protecting privacy, civil
rights, and civil liberties; and
(iv) such other best practices as the
Secretary determines appropriate; and
(D) carry out such other activities as the
Secretary determines appropriate.
[(j)] (k) Definitions.--In this section--
(1) the term ``fusion center'' means a collaborative
effort of 2 or more Federal, State, local, or tribal
government agencies that combines resources, expertise,
or information with the goal of maximizing the ability
of such agencies to detect, prevent, investigate,
apprehend, and respond to criminal or terrorist
activity;
(2) the term ``information sharing environment''
means the information sharing environment established
under section 1016 of the Intelligence Reform and
Terrorism Prevention Act of 2004 (6 U.S.C. 485);
(3) the term ``intelligence analyst'' means an
individual who regularly advises, administers,
supervises, or performs work in the collection,
gathering, analysis, evaluation, reporting, production,
or dissemination of information on political, economic,
social, cultural, physical, geographical, scientific,
or military conditions, trends, or forces in foreign or
domestic areas that directly or indirectly affect
national security;
(4) the term ``intelligence-led policing'' means the
collection and analysis of information to produce an
intelligence end product designed to inform law
enforcement decision making at the tactical and
strategic levels; and
(5) the term ``terrorism information'' has the
meaning given that term in section 1016 of the
Intelligence Reform and Terrorism Prevention Act of
2004 (6 U.S.C. 485).
[(k)] (l) Authorization of Appropriations.--There is
authorized to be appropriated $10,000,000 for each of fiscal
years 2008 through 2012, to carry out this section, except for
subsection (i), including for hiring officers and intelligence
analysts to replace officers and intelligence analysts who are
assigned to fusion centers under this section.
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