| U. S. Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives Office of the Director Washington. DC 20226
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The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) appreciates the opportunity to provide comments on areas of concern involving the Office of the Inspector General's (OIG) draft report, detailing a review of the Violent Crime Impact Team (VCIT) initiative. We agree with all of the recommendations in the OIG report. In fact, ATF is currently implementing several of the suggested improvements similarly discovered as a result of our independent evaluation of the VCIT pilot program conducted prior to, and concurrent with, the OIG's review. These findings were first published in December 2005, in Violent Crime Impact Teams, Best Practices (ATF Publication 3501.1) and are an attachment to this response. This memorandum addresses each OIG recommendation and details the actions ATF has taken to mitigate issues identified in the report. Although ATF stands in agreement with the OIG recommendations that chart the future for the VCIT program's expansion, ATF disagrees with the findings used to support these conclusions. ATF's primary disagreement is founded on the fact that the VCIT program was a 6-month pilot program actively under review by ATF at the time of the OIG audit and that criticisms regarding implementation of a program under design are premature. For the purposes of responding to these findings, ATF addresses the two areas of greatest concern to the OIG as defined by ATF: performance measurement and program implementation. PERFORMANCE MEASUREMENT ATF knows that the public expects law enforcement institutions to prevent crime. ATF therefore creates enforcement programs intended to prevent crimes committed with firearms, explosives, and fire. Success of ATF programs is measured not solely by outputs, such as the number of convictions achieved or arrests made, but by reductions in the number of crimes ATF special agents and their enforcement partners work jointly to prevent. We agree with the OIG's position that the measurement of these outcomes is problematic at best. It may also be true that a direct causal relationship between ATF programs and reductions in crime can never be established. However, an abundance of evidence already exists that ATF is an integral player in a Department of Justice (DOJ)-wide strategy that is contributing to historic reductions in violent crime through support of the President's Project Safe Neighborhoods (PSN) initiative and, more recently, through VCIT, a companion initiative to PSN that has contributed to a significant decline in homicides. In 2000, the year prior to implementation of PSN, 533,470 persons were victims of gun crime. In every year thereafter, fewer victims of firearms violence have been reported, reaching a low of 280,890 in 2004, representing a nearly 50 percent decline. Although the track record for VCIT is not nearly as lengthy, the results attributed to the program are impressive. Following only several months of operations, homicides in VCIT cities declined by more than 8 percent, a rate of decline five times the average of other American cities. Although it is uncertain to what degree ATF is specifically responsible for the decline in homicides and overall violent crime, it is clear that ATF has played its part and has contributed to a safer America. ATF programs have saved lives. The difficulty of measuring law enforcement success through crime prevention should not prevent ATF from building programs that support the goals shared by our State and local partners, as well as the members of the public we are collectively sworn to protect. ATF's unique approach should encourage necessary debate by decision makers who must judge which Federal programs provide the most value in increasing public safety and the quality of life in our communities. As a law enforcement organization, ATF is not alone in its belief that Government programs and strategies can prevent crime. The Uniform Crime Report (UCR) produced by the Federal Bureau of Investigation (FBI) cites many known factors that affect the volume and type of crime occurring from place to place. These factors include the "effective strength of law enforcement agencies"; "administrative and investigative emphases of law enforcement"; as well as the "policies of other components of the criminal justice system (i.e., prosecutorial, judicial, correctional, and probational)" (FBI, UCR, 2004, p. vi.) The FBI's position that the law enforcement community can impact crime through additional resources and purposeful interventions is supported by Larry T. Hoover, Director of the Police Research Center at Sam Houston State University, Huntsville, Texas, who has stated that "one of the most common misconceptions pervading modern criminology is that police make no difference... however, there is consistently accumulating evidence that focused police efforts to reduce particular crimes committed by particular offenders at particular times and places are effective." Hoover advises that virtually every controlled experiment entailing crime-specific interventions has yielded positive results (i.e., crime went down). In other words, "when the police concentrate resources on a particular crime, the incidence of that crime drops." (Police Executive Research Forum Police Program Evaluation, 1998, p.1.) With this knowledge, ATF initiated the VCIT program at the direction of the Deputy Attorney General to mitigate the homicide problem in 15 cities selected by officials from the Office of the Deputy Attorney General (ODAG) and ATF. Members of the ODAG's staff voiced concern that the success of PSN and its impact on overall violent crime was being undermined by the stubborn fact that homicides, including those committed with firearms, continued to rise. ATF agreed to establish a 6-month VCIT pilot using $499,000 and additional personnel in 15 cities in a proactive attempt to prevent homicides. Following ATF's intervention, the 15 VCIT cities witnessed a remarkable decline in homicides compared to cities without VCITs in other parts of the Nation. It is also true that these l5 cities, as a group, represented some of this Nation's most violent areas. Based on UCR data for the 3 calendar years preceding the 6-month pilot project, the 15 cities selected by ODAG experienced an 11.4 percent increase in homicides, as compared to all other cities measured by the UCR, which saw a 4.7 percent increase during the same period (Chart 1).
The VCIT program attempted, through a crime-specific intervention, to prevent homicides, particularly those committed with firearms. Specific offenders were targeted; those most likely to use a firearm to kill someone and not necessarily those with the longest rap sheet. Specific areas were targeted; those that seemed to be the hot spots where murders were committed, and in particular, those committed with guns. Additional resources were provided; in particular, special agents were detailed to VCIT cities, new partnerships were established, and teams adjusted work schedules to work on days of the week and during periods of the evening when homicides were most likely to occur. By the conclusion of 2004, the number of homicides in the 15 cities declined dramatically when compared as a group to the remaining cities in the United States that had not received VCIT intervention. Based on UCR data for 2004, homicides in VCIT cities declined 8.2 percent, while cities without VCIT declined 1.5 percent. The only commonality known to evaluators among these 15 cities, which collectively saw a homicide reduction five times that of other cities in America, was VCIT intervention, which was implemented with the sole purpose of producing this effect (Chart 2).
PROGRAM IMPLEMENTATION The OIG recognizes that the VCIT strategy may be an effective tool to reduce violent crime in target areas and criticizes ATF on its implementation of the strategy. We agree that VCIT does prevent crime but believe our implementation strategy was under design when reviewed and this criticism, therefore, is premature. ATF concurs that a detailed strategy is important in the implementation of the VCIT initiative but reiterates that the goal of the pilot program was to determine which elements of the program were effective and should be included in future implementation. Therefore, field offices were given the flexibility to determine which elements were key and were not required to continue to implement elements that were determined to be unnecessary. In June 2004, ATF designed VCIT to give ATF field offices guidance on implementing a new strategy to lower the number of homicides. The program was designed to run for a 6-month pilot period until December 2004, when it would be reviewed to determine if ATF resources should continue to be allocated to the VCIT program. ATF's objective during this pilot period was to determine if ATF could affect the number of homicides in specific high-crime areas. The report does not address these facts. The VCIT strategy was designed to give a framework to local field offices so that they could model their implementation around the aspects of the program that actually worked in their area. This was a significant lesson learned from PSN that saw benefits to avoiding a one-size-fits-all approach to program implementation. ATF recognized that certain aspects of the VCIT strategy would be more effective in different areas of the country and that it was essential to give special agents in the field the ability to tailor the VCIT strategy locally and specifically to the communities they serve. ATF believed that allowing field offices this f1exibility would enable ATF to determine which aspects of the strategy were effective and which were not. ATF developed a VCIT strategy prior to the implementation of the pilot program that suggested six elements ATF initially believed to be important parts of the VCIT strategy. VCIT cities were tasked with implementing all of these elements and determining which ones were effective in their area. Subsequent to the VCIT pilot period, ATF conducted an extensive review of each VCIT city's performance to determine, simply, "what is working and what is not." The review consisted of after-action reports, as well as extensive interviews with VCIT supervisors and representatives from participating law enforcement agencies. In December 2005, ATF published Violent Crime Impact Teams, Best Practices, which outlined the ten best practices used in VCIT cities that ATF believed were effectively impacting violent crime and contributing to reductions in homicides. The OIG review, dated April 2006, lists five key elements believed to be the most important to the implementation of the VCIT strategy. TABLE A
Table A illustrates the chronology of the elements of implementing the pilot, as well as the concurrent review and documentation of the key elements identified by the OIG and the best practices documented by ATF. The table is illustrative of the fact that ATF had implemented an effective review of the pilot program to determine the elements of the VCIT program that are effective and should be implemented in all VCIT cities in the future. ATF is cognizant that practitioners responsible for programmatic evaluation recognize four types of reviews: Front end Evaluations, Formative Evaluations, Monitoring Evaluations, and Summative Evaluation. Different approaches will produce different results. It is also fair to state that different approaches are more suitable for different stages in the life cycle of a program. The OIG conducted a Formative Evaluation during which the traditional goals of process assessment (where determinations regarding implementation and operations are investigated) and evaluability assessment (where determinations regarding the feasibility of various evaluation methods are detailed) were employed, and findings based on this approach were logically presented. The OIG acknowledged that it rarely, if ever, has reviewed a program during its pilot phase of operations. VCIT was reviewed in the same fashion as other Government programs that have operated for many years. In contrast, ATF conducted a Front-end Evaluation (where a needs assessment would have been the traditional approach for an inquiry of its kind) prior to the formal implementation of the program. Formal implementation of the program first began in earnest during fiscal year (FY) 2006, in response to findings first published within an extensive Best Practices review released in late 2005, as well as the dedication of significant financial resources as a result of late FY-05 reprogramming and FY-06 funding. When the reviews are compared (Table A, columns 1 and 2), it is clear that the OIG evaluated ATF based on the implementation of its initial pilot framework, an exploratory approach to determine if teams dedicated to reducing homicides could succeed. In contrast, ATF approached the initial pilot as an exercise to determine best practices; hence, far different and more comprehensive conclusions were reached. ATF purposely chose to conduct a Front-end Evaluation to encourage field divisions to try different methods within the VCIT Strategy so that evaluators could determine what worked and what did not prior to formal implementation of the program. In Baltimore and Los Angeles, where ATF's published findings suggested VCIT had failed to adequately contribute to a reduction in homicides, ATF leaders directed significant changes in strategy, resulting in improved short-term results. In Chattanooga, the program was viewed as an inappropriate means to combat local crime problems; and with the agreement of local ATF and police officials, the program was terminated. In the remaining 16 cities, operations have been refined to replicate past successes. There is no disagreement over recommendations that guide the future expansion of the program and serve as the basis of the Monitoring and Summative Evaluations of tomorrow. Once again, as Table A clearly illustrates, ATF recognizes the importance of programmatic evaluation and appreciates the constructive criticism of the VCIT program by the OIG both where it mirrors ATF's findings and where it differs from our experiences in the field. When the complementary reviews are juxtaposed, we believe that the table collectively serves as a constructive outline for future VCIT efforts. In its field site visits, the OIG conducted numerous in-person interviews with personnel from ATF, the Drug Enforcement Administration (DEA), the United States Marshals Service (USMS), and other Federal, State, and local law enforcement partners, but did not incorporate into the document the positive feedback from these partners. OIG audit team members specifically stated (on numerous occasions to a number of interviewees) that their interviews with "all levels" of personnel revealed a consistent theme - that this program was an effective program. TARGET SMALL GEOGRAPHIC AREAS With regard to targeting specific (not small) geographic areas, the Executive Digest misrepresents many of the site-specific details. The Executive Digest (Page ix) suggests that the target areas varied in size but fails to concede that 18 of the 19 cities (95 percent) considered identifying and working within a defined target area as a core component (key element) of their VCIT initiative. Similarly, 18 of 19 (95 percent) cities surveyed responded that their VCIT targets or operates in a specific geographic area(s) (i.e., "hot spots"). This is consistent with the original VCIT strategy. While ATF agrees that some cities may have initially selected a larger area than might be ideal and concurs that a small area may be a reasonable recommendation, to represent this as a "key element" in the implementation of the pilot misrepresents the strategy. To further illustrate the OIG's contention that VCITs targeted areas that varied greatly in size, information is presented regarding the areas of operation as opposed to the targeted areas. The report does not identify that cities whose operations encompassed the entire city did target identified geographic hotspots (with one exception). Specifically, Chattanooga and Miami are represented in the OIG supporting documentation as having "target areas" of the entire city and county (respectively) when both of these VCITs articulated in the OIG surveys that they did target specific hot spots. Target the Worst Violent Offenders The OIG survey questioned whether VCITs used a "worst of the worst" list and allowed for those who responded negatively to explain their reasons. The OIG survey results suggest that 13 out of 19 VCITs used a "worst of the worst" list but also uncovered the reason why these lists were not used (when they were not). It warrants recognition that the predominant reason for not using the lists was to ensure participation by partners who were key to the success of VCIT. The OIG makes two assertions regarding the targeting of the worst violent offenders that conflict with the strategy:
BUILD EFFECTIVE WORKING RELATIONSHIPS WITH COMMUNITY LEADERS ATF concurs that community outreach is an important component toward affecting lasting success of violence-reducing initiatives including VCIT. ATF does not concur, however, that the VCITs did not incorporate community outreach into their strategies. VCIT has always been a component of the PSN strategy. When considering the operations in their totality, including the complementary efforts of PSN, almost every VCIT had elements of outreach. For example, the review suggests that during the site visits, the OIG found that only one of the five VCITs actively continued to participate in any community outreach. Each of the four cities that are identified as not participating in community outreach either have direct community outreach or have a complementary outreach mechanism in place through which community outreach is a contributing element to the strategy. For example, the OIG review states that the Tampa "... VCIT did not engage in community outreach activities." (page v) Further review of the ATF activities in Tampa would reveal participation in community outreach programs, including "Drug-Free Kids" and the "Great American Teach In." The OIG review states that the Tucson VCIT did not engage in community outreach activities. Further review of activities in Tucson reveals that ATF did participate in community outreach activities, such as joining the Tucson Police Department during their "Community Night Out." This was in addition to numerous meetings, strategy sessions, presentations and speeches between May 2004 and September 2005. UTILIZE ATF' S INVESTIGATIVE TECHNOLOGY RESOURCES The OIG review states"... we determined that VCITs did not consistently use the services of the National Tracing Center (NTC), the National Integrated Ballistics Information Network (NIBIN), and the Crime Gun Analysis Branch (CGAB) to facilitate their investigations.". ATF does not agree with the OIG's characterization of the VCITs' use of ATF's technology resources. The Executive Digest does not fully present much of the site-specific details and does not incorporate the full results of the review. Although the OIG survey did not pose the question whether VCITs felt utilization of technology was a key element of their VCIT initiative, the OIG survey did reveal extensive use of the technologies by ATF. Specifically, the OIG survey revealed the following:
ATF will continue to direct the VCITs to utilize technology in support of their mission but believes the use of technology within VCIT cities is mischaracterized in the report. ATF is specifically concerned that some of the characterizations may have arisen from misunderstandings about ATF protocols for firearms tracing and NIBIN utilization. For example, the contention that VCITs underutilized NTC services is largely premised on the fact that they did not utilize the "urgent" identification for all of their traces. ATF policy outlines that traces should be classified as urgent for time-sensitive requests, such as homicide of a police officer, assassination attempts of public officials, and violent incidents of national significance (e.g., Columbine). NTC officials did provide instruction to those processing trace requests that VCIT firearms traces could be expedited without meeting the identified criteria for "urgent" requests. While the VCITs were not specifically instructed to mark trace requests as "urgent" for all recovered firearms, there was inconsistency in the use of this NTC service. Further, ATF does not necessarily interpret a decline in trace requests to mean that there was an inconsistent or declining use of NTC services. Trace requests are incident driven and will fluctuate with firearms recoveries over time. Simply put, if fewer firearms are recovered, fewer traces will be submitted. ATF has similar concerns with the assessment of VCIT use of NIBIN. Like tracing, NIBIN is incident driven. NIBIN usage is limited to the volume of ballistic evidence recovered in a given period of time. In addition, the OIG evaluation of NIBIN use does not address seasonal variations in evidence retrieval (comparing July-December 2004 to January-June 2004). ATF also took note of the fact that the time period the OIG assessed is different from the pilot period (June-November 2004), which we fear could potentially mislead the report audience. Should this data reveal anything, ATF would suggest that this could be evidence of a decline in the instances of shootings, a goal of the program. When considering the operations in their totality, including the complementary efforts of local crime analysts and local Regional Crime Gun Centers, every VCIT utilized crime gun analysis. The entire picture should be considered when reviewing the use of CGAB. In response to the OIG survey, seventeen of the nineteen VCIT coordinators (89 percent) stated that they used CGAB (one of those who responded negatively was Los Angeles, which has similar services provided by a Regional Crime Gun Center). WORK IN PARTNERSHIP WITH OTHER DEPARTMENT LAW ENFORCEMENT COMPONENTS The Executive Digest provides the key element as "coordinate law enforcement efforts across agencies" (Page ii), followed in the review as "work in Partnership with Other Departmental Law Enforcement Components." ATF views these as two different things by which to judge the implementation of the program. ATF certainly agrees that full participation by our partner law enforcement agencies is important to the VCIT strategy, but to base judgment of ATF's implementation of the VCIT pilot on this fact does not reflect that the VCIT strategy and the OIG interviews with ATF officials identified local law enforcement as the most critical law enforcement partnership in support of the success of VCIT. Additionally, ATF is concerned with the representation made as to the level of participation across the cities. The OIG survey posed this question for two separate time periods, including during the pilot period and at the time of the survey in September 2005. The OIG used information based on the site visits that spanned yet another time period. Data is used from each of these different points in time to support the assertions of lack of participation by Departmental law enforcement. Of greatest concern is the representation of participation in site visits that is not consistent with what ATF officials in the field report as participation levels. For example, the OIG suggests that the Tucson "... VCIT did not include special agents from the DEA or the FBI, Deputy U.S. Marshals, or AUSAs." ATF officials overseeing Tucson provided information contrary to this, that currently there is one DEA special agent assigned fulltime who is available anytime he is needed, and a U.S. Marshal assigned and working every day on the task force. The OIG survey also identified the following participants during the pilot period: three full-time AUSAs, one DEA special agent, one U.S. marshal, four city police department officers, one Pima County attorney, one Pima County adult probation officer, one U.S. probation and parole officer, and one Arizona Criminal Justice Commission representative. Additionally, the VCIT has worked with the Arizona Board of Parole and Probation. RELEASE OF UNVALIDATED NUMBERS Lastly, ATF feels it critically important to reiterate that the OIG should not base any tables or analysis on unvalidated figures (see Table 2 in Executive Digest of the OIG review, Figure 4, Table 7, and Table 8 in the OIG review). These figures are presented as "ATF data" and in tables identified as "the OIG analysis" throughout the report. All data released by ATF underwent a thorough validation with the local police departments, and NONE of this data has been verified or validated (with the exception of the homicide by firearms over the 6-month pilot period and the compared 6-month period in 2003). ATF made a commitment to its local partners that only verified information would be released for public consumption and has made this clear to the OIG. If these numbers are to be used, we ask that the OIG validate these numbers with the local police departments. We thank you for your consideration of our concerns as articulated above. RECOMMENDATIONS As mentioned previously, we agree with the OIG's recommendations and have already implemented many of the findings below:
ATF concurs. VCIT was a pilot program and following the initial 6-month implementation of VCIT, ATF engaged in an in-depth assessment. As previously noted, ATF has published and distributed Violent Crime Impact Teams, Best Practices for the very purpose of establishing specific operational guidelines for VCIT implementation. ATF convened two VCIT meetings, August 16 and 23, 2005. During the meetings, each VCIT supervisor presented and fully articulated his/her team's strategy, and preliminary copies of the VCIT best practices document were provided to each supervisor. Presentations on the VCIT strategy, reporting requirements, NIBIN, and operational guidelines for VCIT implementation were made by representatives of ATF's Office of Field Operations and Office of Enforcement Programs and Services. Current operational guidelines for VCIT, as outlined in VCIT Best Practices Numbers 1 through 10, have been established as the basic tenets for all VCIT cities. Prior to the implementation of each VCIT, ATF executive leadership and ODAG senior staff met with senior representatives from all partner agencies. ATF will continue this practice to ensure that VCIT initiatives are tailored to local crime problems and address the concerns of local communities. Each Division's implementation of this initiative may vary, dependant on particular jurisdictional needs, but will adhere to the Best Practices framework.
ATF concurs: ATF has canvassed each of the ATF SACs requesting a preliminary analysis to form a pool of potential future VCIT cities. These site surveys address crime rates; exact nature of the crime problems in each city; the specific size and location of the proposed VCIT area; and the level of support anticipated from other law enforcement agencies. In addition, ATF, in concert with the Attorney General's Anti-Gang Coordination Committee, participated in the development of the Anti-Gang Coordinating Committee Gang Threat Assessment and Law Enforcement Activity Recommendation. This Recommendation would be used as a template for the submission of all future VCIT sites before an Anti-Gang Task Force Subcommittee for consideration of expanding the program to a new city. The Recommendation is a thorough assessment, an analysis of ongoing law enforcement and task force operations, and a specific plan of operations, including the proposed area of operations and specific goals of the proposed task force. The Recommendation also requires the concurrence of the local U.S. attorney, DEA SAC, FBI SAC, U.S. Marshal, and police chief. The Anti-Gang Task Force Subcommittee will consist of one representative each from ATF, FBI, USMS, Executive Office of United States Attorneys, and DOJ's Criminal Division, and will review and approve all future VCIT sites.
ATF concurs. ATF realizes that the overall program evaluation will hinge on official, validated crime data as reported through the FBI's Uniform Crime Report (UCR). The VCIT was a pilot program developed in response to a request from DOJ to address unacceptable levels of homicides. The goal of the VCIT pilot program was to determine if the VClT strategy could be effective at reducing homicides by focusing efforts and resources on hot spots where homicides most frequently occur. ATF considered the following four sets of data:
Each one of these is a valuable indicator of whether or not the VCIT program is having an effect but, considering ATF's firearms jurisdiction, ATF determined that any evaluation should be measured by its impact on firearms-related crimes. ATF concurs with the OIG report and agrees that the best overall evaluation of the VCIT program's success would be the number of violent criminal acts with a firearm. However, it was determined that these numbers could not be satisfactorily validated until the underlying data that make up the UCR issued by the FBI was released to law enforcement for analysis. The VCIT pilot program took place from June - December 2004. As of the date of this report, the UCR data for this time period is still not available for dissection; therefore, ATF clearly could not evaluate the 6-month VCIT pilot program on this measurement, nor could strategic adjustments be made to the program based upon this data. As soon as the data becomes available, ATF will evaluate these numbers and discern if any correlation can be made between the implementation of the VCIT program and the resulting firearms-related violent crime data. Because of the data's unavailability, the only option remaining was to look at the data set of homicides committed with a firearm. This data set is easily validated by local law enforcement and can therefore be used in a timely manner to obtain a snapshot of crime trends in a specific area. Academics have also found that homicide data is the most accurate crime data available, as it can be more easily validated with coroner and hospital data and less likely to be miscoded by law enforcement personnel. While we acknowledge that the number of homicides committed with a firearm can be a small number in some locations, when the data is analyzed over the 15 VCIT cities and compared to the rest of the cities in the United States, ATF feels that any large difference in a trend is statistically significant. Additionally, this measure goes directly to the stated mission of VCIT to reduce homicides. Although firearms-specific data for 2004 is not yet available, official UCR data for total homicides is available. Chart J shows the number of homicides committed in the 15 VCIT cities from 2001-2004 as compared to the number of homicides committed in every other city in the United States over the same period. The data was obtained from the correlating UCR for each year. As previously noted, UCR data for the 3 calendar years preceding the 6-month pilot project reflect the 15 VCIT cities' 11.4 percent increase in homicides as compared to all other cities measured by the UCR, which saw a 4.7 percent increase during the same period. The homicide rate for these cities during the time the VCIT pilot program was operating fell 8.2 percent as compared to a decrease of 1.5 percent in all other U.S. cities. These numbers are dramatic. The incontestable fact that the number of homicides decreased 5.5 times faster in these 15 cities than in the rest of the United States, accounting for 41 percent of the total national decline in homicides, seems beyond mere coincidence or happenstance. ATF does not claim that the VCIT pilot program alone was responsible for these results but recognizes these results constitute a unique and positive occurrence, particularly for the residents of these communities. ATF looks forward to the opportunity to explore more fully the factors that influenced these historic reductions in crime as fire arms specific UCR data and more data points become available. ATF believes that these measurements were the only way to evaluate the VCIT program in its infancy until validated UCR data becomes available from the FBI. Given the limits of "real-time" crime data, these measures seem appropriate given the VCIT mission to reduce the incidents of homicide.
ATF concurs. ATF has developed uniform memorandums of understanding (MOUs) for all future VCIT operations. Drafts of these MOUs are currently being reviewed by ATF counsel. These MOUs, combined with the use of the aforementioned Anti-Gang Coordinating Committee Gang Threat Assessment and Law Enforcement Activity Recommendation, which requires the concurrence of all local law enforcement agency heads - Federal, State, and local - with the establishment of future VCIT operations and their scheme of operations, will accomplish this goal. ATF is also pleased that both the DEA and USMS have advised that they each intend to request two full-time special agent positions to serve on each of 40 VCITs as a part of the fiscal year 2008 budget process. Discussions continue with the FBI concerning joint efforts between VCIT and Safe Streets Task Forces.
ATF concurs. VCIT was a pilot program that deliberately provided broad guidance regarding operations. This was intended to both gauge what practices would prove most successful and to allow each community to address specific issues and unique problems that were the root causes of its violent crime problems. For example, it is not important that a VClT group maintain a list formally known as the "Worst of the Worst Offenders List," as long as that group establishes a method with its law enforcement partners to identify, investigate, and arrest the most violent and egregious offenders - those persons most likely to commit a homicide. The publication and adoption of the VCIT best practices document has been and will continue to be utilized to establish clear operational guidelines for the implementation of VCIT operations. In addition, all ATF field divisions are required to submit biannual strategic plans that address or reevaluate their current crime problems, target areas, and concepts of operation.' ATF field divisions must also submit written justification to substantially vary from the approved VClT strategic plan. For example, written justification would be needed to change the targeted area. All VCITs are required to submit weekly workload statistics on arrests, traces, and seizures, as well as monthly performance reports on outcome-based measures such as homicides and, where available, violent crime. Narratives on successful and significant cases are also required. Feedback on the timeliness of reporting is provided by monthly online scorecards that address current strategic plans, weekly output reporting, narrative reporting, and monthly performance reporting. We thank you again for allowing us the opportunity to provide initial comments on the draft report. As outlined above, we concur with all of the recommendations in the OIG report and have already taken action to implement them. ATF is dedicated to reducing violent crime and making our neighborhoods safer and believe that the VCIT initiative has contributed significantly to this mission. We embrace any opportunity or recommendation that will enable us to improve these efforts and meet the challenges of the future. Please contact us if we can provide further clarification.
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