HomeMy WebLinkAbout065296 - General - Contract - Federal Bureau of Investigation (FBI)COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
CSC No. 65296
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE FEDERAL BUREAU OF INVESTIGATION
AND
CITY OF FORT WORTH ON BEHALF OF THE FORT WORTH POLICE DEPARTMENT
1) PARTIES
(the "Participating Agency")
FOR THE ESTABLISHMENT AND OPERATION OF A
COUNTER-UAS TASK FORCE (CUTF)
This Memorandum of Understanding (MOU) is entered into by and between the
Federal Bureau of Investigation (FBI) and the City of Fort Worth on behalf of the Fort
Worth Police Department (hereinafter, the "Participating Agency"). The FBI and the
Participating Agency are also referred to herein individually as a "Party" or
collectively as the "Parties."
b. This MOU is not intended, and should not be construed, to create any right or
benefit, substantive or procedural, enforceable at law or otherwise by any third
Party against the Parties, the United States, or the officers, employees, agents, or
other associated personnel thereof. No assignment of rights, duties, or obligations of
this MOU shall be made by any Party without the express written approval of a duly
authorized representative of all other Parties.
2) PURPOSE
a. The purpose of this MOU is to formalize the relationship between the FBI and the
Participating Agency to establish a Counter-UAS Task Force (CUTF) and to document
the agreed responsibilities, functions, and procedures of the Parties with respect to
extending federal counter-UAS authorities pursuant to 6 U.S.C. § 124n, as revised by
the SAFER SKIES Act and subsequent guidance published by the Attorney General, to
trained and certified state, local, tribal, and territorial (SLTT) law enforcement
officers for the detection, identification, monitoring, tracking, and mitigation of
unmanned aircraft systems (UAS) that pose a threat to public safety or national
security.
b. This MOU will enhance the effectiveness of federal and SLTT law enforcement
resources through well -coordinated initiatives that seek the most effective avenues
by which to ensure public safety, protect critical infrastructure, and support the
investigation and prosecution of individuals involved in illegal or threatening UAS-
related activities.
OFFICIAL RECORD
CUTF_M0U_Template_v1.0_20260223_OGC-APPROVED CITY SECRETARY Page 1
FT. WORTH, TX
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
3) MISSION
a. The mission of the CUTF is to leverage the collective resources of the Parties for the
prevention, preemption, deterrence, and investigation of:
(1) Terrorist acts involving the use of unmanned aircraft systems that affect
United States interests;
(2) The use of UAS to conduct surveillance, reconnaissance, or intelligence
collection against law enforcement entities or critical assets where such use
poses an identifiable threat to officer safety, operational security, or national
security;
(3) UAS interference with wildland fire suppression, law enforcement operations,
or emergency response efforts;
(4) UAS threats to public safety at special events, mass gatherings, and critical
infrastructure; and
(5) Other criminal or national security threats involving UAS as determined by
the FBI.
b. To further this mission, the CUTF shall serve as a means to facilitate information
sharing, joint training, and coordinated counter-UAS operational responses among
CUTF participating agencies.
c. Nothing in this MOU shall be construed to authorize counter-UAS activities directed
at UAS operations that constitute the lawful exercise of First Amendment rights,
including newsgathering and the observation or recording of law enforcement
activities in public spaces. All counter-UAS operations by the CUTF must be
conducted in accordance with federal law, and applicable policies of the Department
of Justice and Federal Bureau of Investigation.
4) AUTHORITIES
The FBI is authorized to coordinate intelligence, investigative, and operational
responses to various criminal, cyber, and national security threats pursuant to: Title
28, United States Code § 533 (Investigative and Other Officials; appointment); 34
U.S.C. § 10211 (Training and Manpower Development); 28 C.F.R. § 0.85 (General
Functions, Director, FBI), 0.85(I) (Primary Jurisdiction in Terrorism Matters); 18 U.S.C.
§ 3107 (Services of Warrants and Seizures by FBI); 18 U.S.C. § 3052 (Powers of the
FBI).
b. Pursuant to 6 U.S.C. § 124n, as revised by the SAFER SKIES Act, the FBI's federal
counter-UAS authorities may be extended to qualified and federally deputized SLTT
law enforcement personnel. Participating personnel must be trained and certified
through the National Counter-UAS Training Center (NCUTC) Counter-UAS System
Operator (CUSO) course, except as otherwise provided in Section 7 of this MOU.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 2
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
c. Additional authorities include: Executive Order 12333, as amended; the Attorney
General Guidelines for FBI Domestic Operations (AGG-DOM); applicable Homeland
Security Presidential Directives (HSPDs) and National Security Presidential
Memoranda (NSPMs), including NSPM-36; and 18 U.S.C. § 1030.
5) SUPERVISION AND CONTROL
a. FBI Headquarters (FBIHQ), through its Critical Incident Response Group (CIRG),
retains responsibility for program management, policy direction, and programmatic
standards governing all counter-UAS task forces established under this authority.
Operational direction of the CUTF shall reside with the Special Agent in Charge of
the Dallas Field Office, exercised through the following chain of command: Special
Agent in Charge (SAC), Assistant Special Agent in Charge (ASAC), and CUTF
Supervisory Special Agent (SSA). The SAC shall designate one SSA to supervise day-
to-day operational and investigative matters pertaining to the CUTF. All operational
activities shall conform to the policies, standards, and directives issued by CIRG.
b. CIRG's Counter-UAS Operations Unit (CUOU) shall provide operational oversight for
the CUTF. All counter-UAS activities conducted under this MOU, including but not
limited to detection, identification, monitoring, tracking, and mitigation operations,
must be approved by the CUOU and conducted in accordance with the FBI Counter-
UAS Policy Guide, applicable Attorney General regulations, and SAFER SKIES Act
implementation guidance. No counter-UAS mitigation activity shall be initiated
without prior CUOU authorization, except in exigent circumstances as defined in the
FBI Counter-UAS Policy Guide, in which case the CUOU shall be notified at the
earliest practicable opportunity.
c. All CUTF personnel will fall under the supervision of the FBI for the duration of
designated CUTF activity only, or when conducting similar related counter-UAS
actions at a related event, incident, or intelligence -driven activity. Designated CUTF
activity is defined as: a planned counter-UAS operation or activity, an emergency
counter-UAS response, or other threatening UAS incident or intelligence threat -
driven activity.
d. All guidance on investigative matters handled by the CUTF will be issued by the
Attorney General (AG), the U.S. Attorney's Office, or the FBI. The FBI will make
available to the Participating Agency applicable guidelines and policies, including the
AGG-DOM and the FBI's Domestic Investigations and Operations Guide (DIOG).
e. The relevant CUTF SSA will be responsible for opening, monitoring, directing, and
closing CUTF investigations in accordance with existing FBI policy and the applicable
United States AG Guidelines.
f. Assignments of cases and operational duties to personnel will be based on, at a
minimum, experience, training, certification status, and performance, in addition to
the discretion of the relevant CUTF SSA.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 3
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
g. Each participant will continue to report to his or her respective agency head for
matters not detailed in this MOU and will be subject to the personnel rules,
regulations, laws, and policies applicable to those agencies.
6) STAFFING COMMITMENT AND RESPONSIBILITIES
In light of the significant cost and effort in on -boarding new CUTF personnel, as well
as the need for continuity to successfully combat national security, criminal, and
UAS-related threats, the Participating Agency agrees to provide its personnel to the
FBI CUTF for a period of at least one year(s). This MOU imposes no maximum limit as
to the time that any individual may remain on the CUTF. The FBI retains discretion
over the length of service of CUTF personnel, in coordination with the Participating
Agency.
b. This is a part-time task force assignment. There is no expectation of overtime. CUTF
personnel will be activated for designated CUTF operations, training events, and
other mission requirements as coordinated between the CUTF SSA and the
Participating Agency.
c. During periods of heightened threats and emergencies, the CUTF may need to
operate 24 hours a day for an extended period of time. During these periods, all
CUTF personnel are expected to support CUTF activities unless released to the
Participating Agency. Such activations will be directed by the FBI field office in
coordination with FBIHQ, through CIRG.
d. CUTF personnel must adhere to the FBI's ethical standards and the Supplemental
Standards of Ethical Conduct for employees of the Department of Justice (DOJ), and
the same rules and regulations as FBI employees with regard to security policies,
conduct and activities while in FBI space, the handling of FBI property, the operation
of FBI vehicles, and the conduct of CUTF business.
e. Continued assignment to the CUTF will be in coordination with the SAC and the
Participating Agency. The FBI SAC retains the discretion to remove any CUTF
personnel from the CUTF.
f. CUTF personnel are subject to removal from the CUTF by the FBI for any violation of
any provision of this MOU, the FBI's ethical standards, the Supplemental Standards
of Ethical Conduct for employees of DOJ, any other applicable agreements, rules,
and regulations, or at the discretion of the FBI.
g. CUTF personnel must sign an acknowledgment of their respective roles and
responsibilities before coming on -board.
h. All CUTF personnel are required to attend FBI legal training in compliance with FBI
regulations and any other training deemed mandatory and/or necessary by the FBI
chain of command. The FBI is responsible for the costs of such training. The
Participating Agency will bear the costs of its own agency -required training,
including the costs associated with initial NCUTC CUSO certification.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 4
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
CUTF personnel may be assigned to support multiple FBI task forces concurrently,
subject to the approval of the relevant task force supervisors and the Participating
Agency. Participation on the CUTF does not preclude assignment to other FBI task
forces, provided such concurrent assignments do not interfere with the personnel's
CUTF duties and obligations.
7) TRAINING AND CERTIFICATION
a. All SLTT law enforcement officers assigned to the CUTF who will operate counter-
UAS systems must be trained and certified through the NCUTC CUSO course as a
prerequisite to operating counter-UAS equipment under federal authority. No
alternative, equivalent, or substitute certification will be accepted in lieu of NCUTC
CUSO certification for the operation of counter-UAS detection or mitigation
equipment under this MOU.
b. Personnel who have not yet completed CUSO certification at the time of assignment
to the CUTF shall be granted a grace period not to exceed 180 days from the date of
assignment to obtain certification. During the grace period, such personnel may
participate in CUTF planning, training, and administrative activities but shall not
operate counter-UAS detection or mitigation systems under federal authority until
NCUTC CUSO certification is obtained.
c. Current NCUTC CUSO certification that remains in good standing is a prerequisite to
any initial or ongoing federal deputation for counter-UAS operations under this
MOU. Lapse of NCUTC CUSO certification will result in immediate suspension of
counter-UAS operational authorities until recertification is achieved through the
NCUTC.
d. The Parties agree that an additional goal of this MOU is to engage in co -training
ventures to ensure continuity and proficiency of responses to incidents involving
UAS threats to public safety and national security.
e. The Parties will meet routinely to discuss and establish training activities and
venues, as well as to discuss other issues of mutual concern regarding counter-UAS
operations. Unless otherwise agreed to, each Party will bear the cost of its own
participation in training exercises.
f. The FBI shall share intelligence information regarding UAS threats and will provide
access to relevant training and information -sharing forums.
8) DEFINITION OF CUTF PERSONNEL
a. As used in this MOU, the term "CUTF personnel" means and includes Task Force
Officer (TFO), Task Force Member (TFM), and Task Force Participant (TFP), as those
terms are defined in the Joint Task Force Policy Guide (1178PG) section 4.3. This
section of the JTFPG is available upon request.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 5
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
9) FEDERAL DEPUTATION
a. Non-federal law enforcement officers participating under this MOU shall be sworn
as Special Deputy United States Marshals to assist with enforcing the United States
Code, including investigative and protective functions via counter-UAS operations
under 6 U.S.C. § 124n, as revised by the SAFER SKIES Act, in connection with the
CUTF activities contemplated by this MOU. The extension of federal counter-UAS
authority to SLTT personnel under this MOU flows specifically through their status as
federally deputized personnel. Deputations are commensurate with the investigative
and operational authority of the FBI, and issued pursuant to 28 C.F.R. § 0.112
(Special Deputation) and 28 U.S.C. § 566.
b. DOJ has limited its commitment to represent task force personnel to those who
were formally deputized by a federal agency, and will require the requesting agency
to demonstrate that a written deputation was in place at the time of the incident in
question. Accordingly, SLTT law enforcement officers must be federally deputized
under Title 18 of the United States Code while assigned to the CUTF. The FBI likewise
requires federal law enforcement officers who serve on the CUTF to be deputized
while so assigned. The FBI will secure the required authorization for deputations, as
needed. Deputations shall remain in effect throughout the tenure of each
individual's assignment to the CUTF or until the termination of this MOU, whichever
comes first.
c. Deputation under this MOU will provide federal authority: (1) for qualifying
individuals to fully participate in all operations and investigations contemplated by
this MOU; (2) to operate counter-UAS detection, identification, monitoring, tracking,
and mitigation systems under federal authority; (3) where the FBI has primary or
concurrent jurisdiction in the matter supported by this MOU; and only (4) when
requested or authorized by the Dallas Field Office.
d. A deputation remains in effect for two years from the date the individual is
deputized by the United States Marshals Service. If an individual deputized pursuant
to this MOU is to continue deputation beyond the expiration date, a renewal may be
requested if all Parties agree. Sponsorship for federal deputations may be revoked
by the sponsoring agency (FBI) at any time, and for any reason, deemed appropriate.
Should the MOU be terminated, or the employing agency withdraw, any FBI
sponsorships of related deputations will be immediately revoked.
e. Parties to this MOU agree to immediately inform the FBI Field Office counter-UAS
coordinator should any deputized individual be removed, transferred, suspended, or
reassigned (for any reason) from duties consistent with this MOU. The granting of a
federal deputy status does not confer any rights upon the receiving individual other
than those outlined herein.
Under the terms of this MOU, the Participating Agency agrees that non -law
enforcement officers detailed to the CUTF will not: (1) participate in law
enforcement activities; (2) carry a weapon, either lethal or non -lethal, during the
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 6
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
performance of CUTF duties; or (3) participate in the execution of search or arrest
warrants.
g. Participating state agencies shall be responsible for cross -deputations for local
officers as permitted or required by state law, and as appropriate.
10) PERSONNEL AND EQUIPMENT
a. The Parties will share available personnel, equipment, resources, and expertise
regarding counter-UAS detection, identification, monitoring, tracking, and mitigation
operations, and the investigation of UAS-related criminal incidents, as necessary.
FBI -Provided Equipment
b. The FBI may provide counter-UAS detection and/or mitigation equipment to the
Participating Agency for use in CUTF operations. All FBI -provided equipment remains
the property of the FBI and shall be used solely for authorized CUTF operations. The
Participating Agency shall safeguard, maintain, and account for all FBI -provided
equipment in accordance with FBI policy. Upon termination of this MOU or the
Participating Agency's withdrawal from the CUTF, all FBI -provided equipment shall
be returned to the FBI in accordance with FBI property management procedures.
Agency -Provided Equipment
c. The Participating Agency may provide its own counter-UAS equipment for use in
CUTF operations, subject to CUOU approval to ensure compatibility, interoperability,
and compliance with federal requirements. The maintenance and repair of all
equipment and property provided by the Participating Agency under this MOU will
be the management and fiscal responsibility of the Participating Agency.
General Equipment Provisions
d. All counter-UAS equipment operated under this MOU, whether FBI -provided or
agency -provided, must be approved by the CUOU and comply with all applicable
federal regulations, including Federal Aviation Administration (FAA) requirements,
National Telecommunications and Information Administration (NTIA) spectrum
management requirements, Federal Communications Commission (FCC)
requirements, and frequency allocation protocols.
e. For official inventory purposes, all equipment including radios, badges, credentials,
and other forms of CUTF identification subject to FBI property inventory
requirements will, upon request, be produced by everyone who participates in the
CUTF.
f. At the completion of an individual's assignment on the CUTF, upon request, or upon
withdrawal or termination of the Participating Agency from the CUTF, all FBI
equipment and property will be returned to the FBI in accordance with FBI policy.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 7
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
g. As this is a part-time task force, the FBI will not provide permanent office space,
vehicles, fuel purchase cards, or communication devices to CUTF personnel. Based
on operational need, the FBI Field Office may provide necessary support during
activated CUTF operations, subject to available field office resources.
11) OPERATIONS AND INVESTIGATIONS
Controlling Guidance
a. Operational and investigative actions, techniques, and procedures will be consistent
with current DOJ guidance, the FBI Counter-UAS Policy Guide, applicable Attorney
General regulations, SAFER SKIES Act implementation guidance, and other applicable
FBI policy. In connection with investigations involving only state violations and state
prosecutions, actions will be consistent with policies and procedures of relevant
state law to the extent they do not conflict with federal requirements under this
MOU.
b. All counter-UAS operations conducted under this MOU are subject to CUOU
approval as set forth in Section 5(b). Only CUTF personnel who hold current NCUTC
CUSO certification and who are federally deputized under this MOU are authorized
to operate counter-UAS systems on behalf of the FBI CUTF.
c. In the event that discrepancies develop between federal and state/local rules,
regulations, statutes, or other state/local practices and policies, federal mandates
will control.
d. At all times, FBI employees are required to comply with all current FBI policies,
irrespective of any discrepancy or conflict with state/local rules, regulations,
statutes, or state/local practices and policies. At all times, non -FBI employees are
required to comply with the policies of their department/agency to the extent they
do not conflict with the terms of this MOU.
Joint Investigations
e. To the extent possible, UAS-related criminal investigations will be jointly performed
by the Parties, with no Party acting independently unless that Party has exclusive
jurisdiction. In circumstances where a matter is best addressed by fewer than all
Parties, non -responding Parties will be promptly notified.
A determination will be made on a case -by -case basis whether to request
prosecution of cases arising under this MOU from federal or state authorities. The
determination will be based on all considerations at issue and may include the
evidence gathered, the potential violations, the sentencing options, and the
amenability of prosecuting authorities to support investigative needs.
g. The Parties understand and agree that all follow-up investigative activities, including
evidence collection, are secondary to public safety concerns, which are paramount.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 8
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
h. Collection of potential evidence pursuant to activities conducted under this MOU
(including by individuals acting under federal deputation) will be accomplished in
conformance with FBI evidence recovery procedures and, unless otherwise agreed
to by the FBI, will be stored and forensically exploited by the FBI.
12) AFTER -ACTION AND OPERATIONAL REPORTING
a. Following any counter-UAS mitigation event conducted under this MOU, the CUTF
SSA shall ensure that a detailed after -action report is prepared and submitted to the
CUOU within the timeframe specified in the FBI Counter-UAS Policy Guide. The after -
action report shall include, at a minimum: the nature of the UAS threat; the counter-
UAS systems employed; the mitigation actions taken; the outcome of the operation;
any injuries, property damage, or unintended consequences; and any lessons
learned.
b. The CUTF SSA shall ensure that all counter-UAS operational activities, including
detection -only operations, are documented and reported to the CUOU in
accordance with the FBI Counter-UAS Policy Guide and SAFER SKIES Act reporting
requirements. Such reporting shall include the type and duration of operations,
systems deployed, and any UAS contacts detected or identified.
c. The CUOU may prescribe additional reporting requirements, formats, and timelines
as necessary to ensure compliance with statutory reporting obligations, including
any reporting requirements under the SAFER SKIES Act and applicable Attorney
General Guidance and federal regulations.
d. The Participating Agency shall cooperate fully in the preparation of all after -action
and operational reports and shall ensure that its CUTF personnel provide timely and
accurate information for inclusion in such reports.
13) SECURITY CLEARANCE AND ACCESS
a. CUTF personnel may require access to sensitive and/or classified information,
classified systems, and/or secure office space in connection with CUTF duties.
Security clearance requirements for individual CUTF personnel will be determined
based on operational need and the specific duties assigned.
b. At a minimum, a Limited Access Request must be submitted and approved for all
CUTF personnel prior to accessing FBI space or FBI systems. A SECRET security
clearance is recommended for all CUTF personnel to facilitate effective participation
in CUTF operations and information sharing. A TOP SECRET clearance with access to
Sensitive Compartmented Information (SCI) may be pursued for personnel whose
duties require access to higher -level classified information, subject to FBI Security
Division approval.
c. All CUTF personnel will execute non -disclosure agreements deemed necessary by
the FBI for the protection of classified and sensitive information, including but not
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 9
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
limited to an SF-312 (Classified Nondisclosure Agreement) and an FD-857 (Sensitive
Information Nondisclosure Agreement), as appropriate to their level of access.
d. Supervisors in the Participating Agency responsible for the CUTF personnel may only
be provided with classified information in accordance with FBI policy, if they have
the appropriate security clearance to receive the classified information, and the
requisite need to know.
e. All members of the CUTF must certify they have not failed an FBI polygraph at any
time. If a potential CUTF member has at one time failed an FBI polygraph, they are
not eligible to be in FBI space and, therefore, not eligible to be a member of the task
force.
The Participating Agency agrees to have CUTF personnel sign an FD-868
(Nondisclosure Agreement for Joint Task Force Members, Contractors, Detailees,
Assignees, and Interns). This action obligates an individual participating in the CUTF,
who is accepting a position of special trust with access to classified and otherwise
sensitive information, to be bound by prepublication review to protect against the
unauthorized disclosure of such information. These provisions are consistent with
and do not supersede, conflict with, or otherwise alter the employee obligations,
rights, or liabilities created by existing statute or Executive order relating to (1)
classified information, (2) communications to Congress, (3) the reporting to an
Inspector General of a violation of any law, rule, or regulation, or mismanagement, a
gross waste of funds, an abuse of authority, or a substantial and specific danger to
public health or safety, or (4) any other whistleblower protection. The definitions,
requirements, obligations, rights, sanctions, and liabilities created by controlling
Executive orders and statutory provisions are incorporated into this agreement and
are controlling.
14) DEADLY FORCE AND LESS -THAN -LETHAL DEVICES
Deadly Force
a. Non -FBI CUTF personnel will follow the Participating Agency's policy concerning the
use of deadly force.
Less -than -Lethal Devices
b. Pursuant to the DOJ Less -Than -Lethal Devices Policy, all state/local officers
participating in CUTF operations must be made aware of and adhere to the policy
and its limits on DOJ officers.
c. The Participating Agency of each individual assigned to the CUTF will ensure the
agency's policies and procedures for use of any less -than -lethal device that will be
carried by CUTF personnel are consistent with the DOJ policy statement on the Use
of Less -Than -Lethal Devices.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 10
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
d. The Participating Agency of each individual assigned to the CUTF will ensure that,
while the individual is participating in FBI -led CUTF operations in the capacity of
CUTF personnel, the individual will carry only less -than -lethal devices the
Participating Agency has issued to the individual, and on which the individual has
been trained, in accordance with the agency's policies and procedures.
15) INFORMATION SHARING, REPORTS, AND RECORDS
a. All investigative and intelligence reporting will be prepared and disseminated in
compliance with FBI policy, including but not limited to DIOG section 14. Subject to
any legal or policy restrictions, copies of documents created for a CUTF matter based
upon information obtained from participation on the CUTF by any CUTF personnel
will be considered to be federal documents under the control of the FBI and shall be
maintained in accordance with FBI records management policy and applicable law.
b. All information learned during the course of a CUTF investigation is subject to FBI
information sharing policies and may not be disclosed outside of the FBI without the
approval of the FBI CUTF Supervisor. CUTF personnel may not disclose any FBI or
CUTF-related information outside of the FBI, including any disclosure to the
Participating Agency, without the prior approval of the FBI CUTF SSA.
c. All CUTF materials and investigative records originate with, belong to, and will be
maintained by the FBI, to include but not limited to MOUs, interview reports (i.e.,
FD-302), interview notes, surveillance logs, subpoenaed records, counter-UAS
operational data, and other investigative information. All information generated in
the course of investigations by the CUTF will be controlled solely by the FBI and may
only be removed from FBI space with the approval of the CUTF SSA.
d. CUTF personnel are strictly prohibited from disclosing any unclassified information
to individuals without a need to know. CUTF personnel are strictly prohibited from
disclosing any classified information to individuals who do not possess the
appropriate security clearance and a need to know.
e. All records prepared and shared among the Parties may not be released or
distributed to third parties or non-parties to this MOU without the express
permission of the drafting agency.
Each Party shall immediately notify the other Parties of any civil, administrative, or
criminal claim, complaint, discovery request, or other request for disclosure of
information (other than the federal Freedom of Information Act), concerning or
arising from operations involving, or conduct of, personnel assigned under this
MOU. Both Parties agree to cooperate fully with one another in the event of any
investigation arising from alleged negligence or misconduct arising from acts or
omissions related to the operational relationship. Nothing in this paragraph prevents
any Party from conducting an independent administrative review of any incident
giving rise to a claim. Any releases of information pursuant to the federal FOIA will
be handled according to the standard FOIA consultation and referral processes
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 11
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
applicable to federal agencies. These equities may include, but are not limited to,
emails and other correspondence between the Parties.
g. CUTF information may identify individuals whose information may be protected by
the Privacy Act of 1974 and "United States persons" whose information may be
protected by Executive Order 12333 (as amended). All such information shall be
handled lawfully pursuant to the provisions thereof.
h. The FBI and the Participating Agency will immediately report to each other every
instance wherein data received from each other is used, disclosed, or accessed in an
unauthorized manner, including any data losses or breaches.
i. The FBI and the Participating Agency agree to abide by the DOJ Privacy, Civil Rights,
and Civil Liberties Protection Policy for the Information Sharing Environment to the
extent that any CUTF-related information is covered by that policy.
16) COUNTER-UAS SENSOR DATA RETENTION AND HANDLING
a. Counter-UAS sensor data, including but not limited to radio frequency (RF) detection
logs, radar data, electro-optical and infrared (EO/IR) video feeds, UAS tracking data,
and electronic signatures collected during CUTF operations, shall be treated as
federal records under the control of the FBI.
b. All counter-UAS sensor data shall be collected, stored, processed, and retained in
accordance with FBI records management policy, applicable federal law (including
the Privacy Act of 1974 and the Federal Records Act), and any specific data handling
requirements set forth in the FBI Counter-UAS Policy Guide and SAFER SKIES Act
implementation guidance.
c. Counter-UAS sensor data that is not associated with an active investigation or
intelligence matter shall be retained for the period specified in the FBI Counter-UAS
Policy Guide or applicable records retention schedule, after which it shall be purged
in accordance with FBI records management procedures.
d. Access to counter-UAS sensor data shall be limited to personnel with a
demonstrated need to know and, where applicable, the appropriate security
clearance. The CUTF SSA shall maintain access controls and audit logs for counter-
UAS sensor data in accordance with FBI policy.
e. Counter-UAS sensor data that may contain information about United States persons
shall be handled in accordance with the minimization procedures required by
Executive Order 12333 (as amended), the Privacy Act of 1974, and applicable
Attorney General guidelines.
The Participating Agency shall not independently retain, copy, or transmit counter-
UAS sensor data collected during CUTF operations without the prior written
approval of the CUTF SSA.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 12
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
17) COORDINATION
a. Intelligence, law enforcement, and operational actions will be coordinated and
cooperatively carried out within the CUTF. The Participating Agency will not
knowingly act unilaterally on any matter affecting the CUTF.
b. The Parties agree that matters designated to be handled by the CUTF shall not
knowingly be subject to non-CUTF or non -FBI intelligence, law enforcement, or
operational efforts by the Participating Agency. All law enforcement actions will be
coordinated and cooperatively carried out.
c. It is expected that the appropriate United States Attorney, in consultation with the
FBI and affected CUTF partners, will determine on a case -by -case basis whether the
prosecution of cases will be at the federal or state level, based upon which would
better advance the interests of justice.
18) INTEROPERABILITY AND DECONFLICTION WITH OTHER FEDERAL COUNTER-UAS
PROGRAMS
a. The Parties acknowledge that multiple federal departments and agencies, including
but not limited to the Department of Homeland Security (DHS), the Department of
Defense (DOD), and the Department of Energy (DOE), possess independent counter-
UAS authorities and may conduct counter-UAS operations in the same geographic
areas or at the same events as the CUTF.
b. Prior to conducting counter-UAS operations at any event, location, or incident where
other federal counter-UAS programs are known or expected to be operating, the
CUTF SSA shall coordinate with the CUOU to ensure deconfliction of counter-UAS
activities. The CUOU shall serve as the primary point of coordination between the
CUTF and other federal counter-UAS programs at the headquarters level.
c. At the operational level, the CUTF SSA shall establish and maintain communication
with counterparts from other federal agencies conducting counter-UAS operations
to ensure that detection, tracking, and mitigation activities do not conflict, create
mutual interference, or result in unsafe conditions. Frequency deconfliction and
spectrum management shall be coordinated through the CUOU and in accordance
with applicable interagency agreements.
d. In the event of overlapping or concurrent counter-UAS operations involving multiple
federal agencies, the determination of lead agency responsibility shall be made in
accordance with applicable Presidential directives, interagency agreements, and the
FBI Counter-UAS Policy Guide. The FBI retains primary counter-UAS responsibility in
matters with a nexus to terrorism or criminal investigation.
e. The Participating Agency shall promptly notify the CUTF SSA of any independent
contact, coordination, or agreement with other federal counter-UAS programs that
may affect CUTF operations.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 13
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
19) LIMITATIONS ON FEDERAL AUTHORITIES
a. The authority exercised by the FBI is primarily derived from federal law, Presidential
directives, and delegations by the Attorney General. No FBI employee or FBI -
sponsored Special Deputy U.S. Marshal under this MOU may exceed those
authorities when acting within the scope of their federal employment.
b. Counter-UAS activities conducted under this MOU are authorized solely pursuant to
the authorities identified in Section 4 and subject to the approval and oversight
requirements of Section 5(b). All such activities must comply with the limitations and
requirements of those authorities, including any restrictions on the types of counter-
UAS actions authorized, the circumstances under which they may be employed, and
the reporting requirements associated therewith.
c. It is understood by all Parties that the FBI maintains primary responsibility as Lead
Agency in all events or incidents with a potential nexus to terrorism and/or involving
a weapon of mass destruction, whether or not UAS are involved.
20) PRESS RELEASES
a. All media releases involving CUTF matters will be conducted by the FBI. No press
release involving a CUTF matter will be issued without prior FBI approval.
b. Any release to the media will be consistent with established press policies of the
investigating Parties in consultation with the appropriate prosecuting authorities.
21) SALARY, OVERTIME COMPENSATION, AND FUNDING
The Participating Agency CUTF personnel will report to their respective agency for
personnel administrative matters. The Participating Agency shall be responsible for
the pay, overtime, leave, performance appraisals, and other personnel matters
relating to its employees detailed to the FBI CUTF. The Participating Agency will, at
their discretion, solicit input from the CUTF SSA for performance appraisals based on
their employees' work on the CUTF.
b. FBIHQ, including CIRG, will not provide funding for vehicles, fuel purchase cards,
communication devices, or similar operational support items for CUTF operations.
Any such costs must be borne by the FBI Field Office from its own resources, the
Participating Agency, or through other applicable task force or interagency funding
mechanisms. Personnel who serve on multiple FBI task forces concurrently may have
access to equipment or resources provided through those other task force
arrangements, subject to applicable policies and approvals.
c. This MOU is not an obligation or commitment of funds nor a basis for a transfer of
funds. Even where one of the Parties has agreed (or later does agree) to assume a
particular financial responsibility, such Party's express written approval must be
obtained before incurring any expense expected to be assumed by the other Party.
All obligations and expenditures by the Parties will be subject to each Party's
respective budgetary and fiscal processes and availability of funds pursuant to all
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 14
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
applicable laws, regulations, and policies. The Parties acknowledge that there is no
intimation, promise, or guarantee that funds will be available in future years.
22) TRAVEL
a. All CUTF-related travel of non -FBI personnel requires the approval of the CUTF SSA
and Participating Agency authorization prior to travel. To avoid delays in operational
travel, the Participating Agency will provide general travel authority to all of its
participating employees for the duration of the employee's membership in the
CUTF.
b. For domestic travel, CUTF personnel will be responsible for appropriate notifications
within his or her Participating Agency, as well as standard FBI travel approvals and
notification. The CUTF will obtain FBIHQ authorization and country clearances for
CUTF personnel required to travel outside the United States. The FBI will pay costs
for travel in accordance with the Federal Travel Regulations of all CUTF personnel to
conduct investigations outside the field office or home agency territory.
23) FORFEITURE
a. The FBI shall be responsible for processing assets seized for federal forfeiture in
conjunction with CUTF operations. Civil judicial and criminal forfeiture are allowed
under 6 U.S.C. § 124n. While it has been contemplated that the FBI would have
administrative forfeiture authority, the regulations have not yet been enacted and
DOJ has not yet authorized use of the statute for administrative forfeiture. Asset
forfeitures will be conducted in accordance with federal law, and the rules and
regulations set forth by the FBI and DOJ. Forfeitures attributable to CUTF
investigations may be equitably shared with the Participating Agency in accordance
with applicable law and DOJ policy.
24) LIABILITY
General
a. The Parties acknowledge that this MOU does not alter applicable law governing any
claim for civil liability arising out of any activity conducted pursuant to this MOU or
otherwise relating to this MOU. DOJ may, in its discretion, determine on a case -by -
case basis that an individual should be afforded legal representation, legal defense,
or indemnification of a civil judgment, pursuant to federal law and DOJ policy and
regulations.
Common Law Tort Claims
b. Congress has provided that the exclusive remedy for the negligent or wrongful actor
omission of an employee of the U.S. Government, acting within the scope of his or
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 15
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
her employment, shall be an action against the United States under the Federal Tort
Claims Act (FTCA), 28 U.S.C. § 1346(b), and §§ 2671-2680.
c. Notwithstanding any other provision contained in this MOU, for the limited purpose
of defending civil claims arising out of CUTF operations, any individual detailed from
a Participating Agency who is acting within the course and scope of his or her official
duties and assignments pursuant to this MOU may be considered an "employee" of
the U.S. government, as defined at 28 U.S.C. § 2671. See 5 U.S.C. § 3374(c)(2).
d. Under the Federal Employee Liability Reform and Tort Compensation Act of 1998
(commonly known as the Westfall Act), see 28 U.S.C. § 2679(b)(1), if an employee of
the United States is named as a defendant in a civil action, the Attorney General or
his or her designee may certify that the defendant acted within the scope of his or
her employment at the time of the incident giving rise to the suit. The United States
can then be substituted for the employee as the sole defendant with respect to any
tort claims alleged in the action. Decisions to certify that an employee was acting
within the scope of his or her employment at the time of the incident giving rise to
the suit, see 28 U.S.C. § 2679(d)(1)&(2), are made on a case -by -case basis, and such
certification cannot be guaranteed.
e. If the Attorney General declines to certify that an employee was acting within the
scope of employment, "the employee may at any time before trial petition the court
to find and certify that the employee was acting within the scope of his office or
employment." 28 U.S.C. § 2679(d)(3).
Individual Caaacity Claims Under The U.S. Constitution or Federal Statutes
f. Liability for violations of federal constitutional law may rest with the individual agent
or officer pursuant to Bivens v. Six Unknown Named Agents of the Federal Bureau of
Narcotics, 403 U.S. 388 (1971). Other federal statutes may also allow for individual
capacity claims against agents or officers acting under color of law.
g. Federal officers enjoy qualified immunity from suit for alleged violations of the U.S.
Constitution and most federal statutes that create an express or implied cause of
action for damages "insofar as their conduct does not violate clearly established
statutory or constitutional rights of which a reasonable person would have known."
Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982).
h. If any Participating Agency's CUTF personnel is named as a defendant in his or her
individual capacity in a civil action alleging constitutional damages as a result of
conduct taken within the scope of CUTF-related duties, the individual may request
representation by DOJ. 28 C.F.R. §§ 50.15, 50.16.
i. An employee may be provided representation "when the actions for which
representation is requested reasonably appear to have been performed within the
scope of the employee's employment, and the Attorney General, or his or her
designee, determines that providing representation would otherwise be in the
interest of the United States." 28 C.F.R. § 50.15(a).
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 16
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
j. A written request for representation by CUTF personnel should be directed to the
Attorney General and provided to the Chief Division Counsel (CDC) of the FBI division
coordinating the CUTF. The CDC will forward the representation request to the FBI's
Office of the General Counsel (OGC), together with a letterhead memorandum
concerning the factual basis of the lawsuit. FBI's OGC will then forward the request
to the Civil Division of DOJ, together with an agency recommendation concerning
scope of employment and DOJ representation. 28 C.F.R. § 50.15(a)(3).
k. If any CUTF personnel is found to be liable for a constitutional tort, he or she may
request indemnification from DOJ to satisfy an adverse judgment rendered against
the employee in his or her individual capacity. 28 C.F.R. § 50.15(c)(4). The criteria for
payment are substantially similar to those used to determine whether a federal
employee is entitled to DOJ representation under 28 C.F.R. § 50.15(a).
Determinations concerning legal representation and indemnification by the United
States are discretionary and are made by DOJ on a case -by -case basis. The FBI
cannot guarantee that the United States will provide legal representation, legal
defense, or indemnification to any federal or state employee detailed to the CUTF,
and nothing in this MOU shall be deemed to create any legal right on the part of any
CUTF personnel.
Express Reservations
m. The Parties do not waive any applicable defenses and/or limitations on liability.
n. Unless otherwise authorized by the FBI, liability for any conduct by CUTF personnel
undertaken outside of the scope of their duties and assignments pursuant to their
federal deputation on the CUTF shall not be the responsibility of the FBI or the
United States.
o. Neither the FBI nor the United States shall be responsible for any liability arising
from the use of an FBI owned or leased vehicle by CUTF personnel while engaged in
any conduct outside the scope of their duties and assignments pursuant to their
federal deputation on the CUTF.
p. To the extent permitted by applicable law, the Participating Agency agrees to hold
harmless the FBI and the United States for any claim for property damage or
personal injury arising from any use of an FBI owned or leased vehicle by CUTF
personnel which is outside the scope of their duties and assignments pursuant to
their federal deputation on the CUTF.
q. It is agreed that the officers, agents, employees, and/or volunteers of the FBI shall
not be deemed employees of the Participating Agency for workers' compensation,
other insurance coverage, or for any other purpose.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 17
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
25) EFFECT OF THIS AGREEMENT
a. This MOU does not constitute an agreement for any Party to assume or waive any
liability or claim under any applicable law.
b. This agreement is not intended to be enforceable in any court or administrative
forum. The Parties will seek to resolve any disputes regarding this agreement by
mutual consultation.
c. This MOU supersedes all other MOUs entered into by these Parties that cover the
same subject matter.
26) DISPUTE RESOLUTION
In cases of overlapping jurisdiction, the Parties agree to work in concert to achieve
the CUTF's mission and objectives. The Parties agree to attempt to resolve any
disputes regarding jurisdiction, case assignments, workload, and other operational
matters at the field level first before referring the matter to supervisory personnel
for resolution.
b. Disagreements between the FBI and the Participating Agency arising under or
relating to this MOU will be resolved only by consultation between the participants
and will not be referred to a court of law or to any other person or entity for
settlement. The final authority to resolve any disputes will be the SAC of the Dallas
Division and the designated head of the Participating Agency.
27) EFFECTIVE DATE, DURATION, AND TERMINATION
This MOU shall be effective when executed by all Parties and will continue in effect
until terminated.
b. This MOU shall be reviewed every three years from its last signature date but may
be terminated at any time upon written mutual consent of the FBI and the
Participating Agency. This MOU will remain in effect until it is terminated by written
mutual consent of the FBI and Participating Agency, or until such time a new MOU is
executed between the FBI and the Participating Agency.
c. Any Participating Agency may withdraw from the CUTF at any time by written
notification to the SAC at least 60 days prior to withdrawal.
d. Upon termination of this MOU, all equipment provided to the CUTF will be returned
to the supplying Party. When a Participating Agency withdraws from the MOU, the
Participating Agency will return equipment to the supplying Party.
e. This MOU shall be reviewed by the designated Points of Contact for all Parties, and
the FBI Chief Division Counsel, no later than every three years from the last
signature date to determine whether this MOU should be revised, continued, or
canceled.
CUTF—MO U_Template_v1.0_20260223_OGC-APPROVED Page 18
COUNTER-UAS TASK FORCE (CUTF) MEMORANDUM OF UNDERSTANDING
28) MODIFICATIONS
a. This agreement in no manner affects any existing agreements with the FBI or any
other agency. This agreement may be amended only by mutual written consent of
the Parties. The modifications shall have no force or effect unless such modifications
are reduced to writing and signed by an authorized representative of the FBI and the
Participating Agency.
29) SIGNATORIES
FBI Dallas Field Office:
By:
Name: R. Joseph Rothrock
Title: Special Agent in Charge
Date:
City:
Contract Compliance Manager:
By signing I acknowledge that I am the
person responsible for the monitoring and
By:
administration of this contract, including
Name:
William Johnson
ensuring all perforinance and reporting
Title:
Assistant City Manager
requirements.
06/03/2026
Date:
&ZL,.t�'
0ao
Kathryn Agee (J . 2026 1 . 1:08 CDT)
By:
Approved as to Form and Legality:
Name: Kathryn Agee
Title: Senior Management Analyst
By:
Keanail tth all (Jun 2. 2026 11:10:21 CDT)
FpgtgYp
City Secretary: °�a,�
Name:
Keanan Matthews Hall
g€ ono
Title:
Senior Assistant City Attorney
O
aoan�ap�a„a
By:
Name: Jannette S. Goodall
Contract
Authorization:
Title: City Secretary
M&C:
N/A
Police Department:
By:
'UNMA4
Dayjd Carab al (Jun 3, 2026 06:15:48 CDT)
Name:
David Carabajal
Title:
Executive Assistant Chief
06/03/2026
Date:
OFFICIAL RECORD
CITY SECRETARY
CUTF_MOU_Template_v1.0_20260223_OGC-APPROVED FT. WORTH, TX Page 19
FORT WORTH.
City Secretary's Office
Contract Routing & Transmittal Slip
Contractor's Name: Federal Bureau of Investigation (FBI)
Subject of the Agreement:
Counter-UAS Task Force MOU to be executed prior to FIFA
M&C Approved by the Council? * Yes ❑ No 8
If so, the M&C must be attached to the contract.
Is this an Amendment to an Existing contract? Yes ❑ No 8
If so, provide the original contract number and the amendment number.
Is the Contract "Permanent"? *Yes ❑ No 8
If unsure, see back page for permanent contract listing.
Is this entire contract Confidential? *Yes 8 No ❑ If only specific information is
Confidential, please list what information is Confidential and the page it is located.
Effective Date: Upon ACM signature
If different from the approval date.
Expiration Date:
Three years following
If applicable.
Is a 1295 Form required? * Yes ❑ No 8
*If so, please ensure it is attached to the approving M&C or attached to the contract.
Project Number: If applicable.
*Did you include a Text field on the contract to add the City Secretary Contract (CSC)
number? Yes 8 No ❑
Contracts need to be routed for CSO processing in the following order:
1. Katherine Cenicola (Approver)
2. Jannette S. Goodall (Signer)
3. Allison Tidwell (Form Filler)
*Indicates the information is required and if the information is not provided, the contract will be
returned to the department.