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The Biden Administration’s Nuclear Weapons Employment Guidance—Increased Cost and Reduced Deterrent Effectiveness
Dr. Mark B. Schneider
Dr. Schneider is a Senior Analyst with the National Institute for Public Policy. Dr. Schneider previously served in DoD as Principal Director for Forces Policy, Principal Director for Strategic Defense, Space and Verification Policy, Director for Strategic Arms Control Policy and Representative of the Secretary of Defense to the Nuclear Arms Control Implementation Commission. He also served in the senior Foreign Service as a Member of the State Department Policy Planning Staff.
In August 2024, it was reported that, “President Joe Biden has approved revisions to a classified nuclear strategic document that redirects Washington’s deterrent strategy to focus on China’s nuclear arsenal expansion for the first time….”[1] In 2024, two senior Biden Administration officials spoke about the possible need to increase the number of U.S. nuclear weapons. The new unclassified Biden Administration nuclear weapons employment guidance report, issued in November 2024, stated “…it may be necessary to adapt current U.S. force capability, posture, composition, or size in order to be able to fulfill the three stated roles of nuclear weapons.”[2] When issuing this report, the Department of Defense stated, “The Guidance also directs that the United States plan to deter multiple nuclear-armed adversaries simultaneously…”[3] This is an important change but the Biden Administration took no action to implement this policy; rather, it left the decision on increasing U.S. nuclear weapons to the incoming Trump Administration.[4]
The Biden Administration’s Unclassified Nuclear Weapons Employment Guidance Report
To its credit, the Biden Administration report stated that, “The Guidance continues to emphasize the need to, first and foremost, hold at risk what adversaries value most. It also reiterates the need to maintain counterforce capabilities to reduce potential adversaries’ ability to employ nuclear weapons against the United States and its allies and partners, and does not rely on a counter-value or minimum-deterrence approach.”[5] It continued:
Updated elements of the Guidance evolved from prior iterations by:
The United States remains resolved to prevent Iran from developing a nuclear weapon and is prepared to use all elements of national power to ensure that outcome.[6]
The Biden Administration adopted conclusions similar to the bipartisan Congressional Commission on the Strategic Posture of the United States concerning the new nuclear threats the United States faces. Its guidance report stated that “…the evidence of growing collaboration and collusion between Russia, the PRC, the DPRK, and Iran makes the situation even more challenging. There is a possibility of coordinated or opportunistic aggression by a combination of adversaries in a crisis or conflict, which requires U.S. strategists to think carefully about complex escalation dynamics and deterring multiple adversaries simultaneously, including in extended crises or conflicts.”[7] However, it took none of the Commission’s report recommendations on enhancing U.S. strategic nuclear deterrence capabilities.[8]
There has been a large reduction in U.S. nuclear weapons numbers and no modernization since 1997. Two of the three best Reagan-era counterforce weapons—the Peacekeeper ICBM and the Advanced Cruise Missile—were eliminated without replacement. The Obama Administration eliminated the nuclear sea-launched cruise missile (nuclear SLCM) and decided on the eventual elimination of all U.S. nuclear bombs that could seriously threaten very hard and very deeply buried bunkers.[9] Without these weapons, U.S. nuclear forces cannot effectively threaten what President Putin values most—his life and well-being because of Russia’s new, deep underground bunkers.[10] The United States does not have sufficient deployed nuclear weapons with the right technical characteristics to deter multiple nuclear adversaries or, indeed, even to target effectively Russia or China alone.[11]
An analysis by the Federation of American Scientists authored by Adam Mount and Hans Kristensen denies that the new Biden guidance shifted emphasis from Russia to China and points out the limits in the changes it mandates. It states the guidance report does not require U.S. forces to simultaneously: 1) “maintain the capability to perform other or all objectives against multiple adversaries…”; and 2) “limit damage against multiple peer adversaries…[or] restore deterrence in the event that it fails….”[12] It notes these objectives necessitate more or better capabilities and that the report did not “effectively endorse” the recommendations of the U.S. Strategic Posture Commission report concerning meeting China’s nuclear buildup.
Moreover, they point out, “The language of the employment strategy report does not clearly indicate whether U.S. forces are required to perform these more demanding objectives. The president could have stated, for example, that U.S. forces are not required to maintain the capability to limit damage against multiple adversaries simultaneously.”[13] The authors note that the guidance “…does not explicitly use the ‘two peer’ description frequently used in the public debate by defense officials and others.”[14]
Even if one takes the Biden Administration’s description of its new guidance at face value, even good changes mandated by it can only partially deal with the rapidly growing multipolar nuclear threats. In 2022, then-STRATCOM Commander Admiral Charles Richard observed:
The key question that the Trump Administration will face is whether the Biden Administration’s changes are actually good ones, or to use Admiral Richard’s metaphor, are simply rearranging the deck chairs on the Titanic?
Both the unclassified guidance report and the classified version of the Biden guidance should be carefully reviewed by the Trump Administration, even before initiating a full scale nuclear posture review. President Trump issued his own nuclear employment guidance report in 2020.[16] Much of it, even if dated, is significantly better, more comprehensive and informative than the Biden version. Some of the new Biden language should be added to it and the bad elements rejected.
Deterring Iran
The Biden nuclear employment guidance report states that, “The United States remains resolved to prevent Iran from developing a nuclear weapon and is prepared to use all elements of national power to ensure that outcome.”[17] However, in December 2024, White House Communications Advisor Rear Admiral (ret.) John Kirby acknowledged that the Biden Administration’s effort to prevent Iran from obtaining nuclear weapons “…didn’t work….”[18] Reportedly, “Mohammad-Javad Larijani, a close aide to Iran’s Supreme Leader Ayatollah Ali Khamenei, made a shocking statement, declaring that Iran could develop military nuclear capabilities within just one day.”[19] The statement in the nuclear employment guidance report that the United States will “…rely on non-nuclear overmatch to deter regional aggression by Iran as long as Iran does not possess a nuclear weapon,” appears to be dangerous wishful thinking.
Dealing with Belarus
Despite joint nuclear strike exercises, Russian provision of tactical nuclear weapons to Belarus, and Belorussian nuclear threats, there is no indication in the unclassified Biden guidance report that it directs nuclear deterrence against Belarus.[20] In December 2024, President Putin stated that Russia may deploy the Oreshnik missile, which Russia had just launched against Ukraine, in Belarus in 2025.[21] The U.S. Department of Defense stated the Oreshnik was “…an experimental intermediate range ballistic missile….based on Russia’s RS-26 Rubezh intercontinental ballistic missile model.”[22] The Oreshnik is nuclear-capable.[23]
Arms Control and Nuclear Deterrence
As the bipartisan United States Strategic Posture Commission pointed out “…there is no prospect of a meaningful arms control Treaty being negotiated with Russia in the foreseeable future…” and that, “Over the past 20 years, Russia has either violated or has failed to comply with nearly every major arms control treaty or agreement to which the United States is or was a party.”[24] It continued, “…given Russia’s history of noncompliance and illegal treaty suspensions, and China’s continued intransigence on arms control dialogue, the United States cannot develop its strategic posture based on the assumption that arms control agreements are imminent or will always be in force.”[25] Pranay Vaddi, then-Special Assistant to President Biden and Senior Director for Arms Control, Disarmament, and Nonproliferation at the National Security Council observed that, “Russia, the PRC and North Korea are all expanding and diversifying their nuclear arsenals at a breakneck pace—showing little or no interest in arms control.”[26] Despite these assessments, the Biden guidance report is unrealistic about the role of arms control in nuclear deterrence. The report states that, “Arms control, risk reduction, and nuclear nonproliferation play indispensable roles as well.”[27] It does not explain why.
Russia continues to violate the New START Treaty by: 1) denying the United States its critical on-site inspection rights, 2) ceasing to provide the legally required notifications, and 3) illegally “suspending” its participation in New START.[28] Russia made the self-serving claim that it is continuing to observe the limitations of the New START Treaty. The U.S. Department of State, starting in its 2023 annual report on the New START Treaty, said that it was unable to certify Russian compliance with the numerical limitations of the Treaty.[29] Thus, the loss of on-site inspections is vitally important as long as the United States imposes the substantive New START limitations on itself. The new Biden Administration’s nuclear employment guidance rewards Russia for violating New START by mandating U.S. compliance with a Treaty Russia is violating.
The Lack of a Programmatic Response to Implement the New Guidance
The Biden Administration has done little to respond to the threats it now assesses. In June 2024, Pranay Vaddi stated that the United States had responded to the increased threat by: 1) pursuing the B61-13 nuclear bomb as a replacement for the “outdated” B83 nuclear bomb, 2) seeking to life extend certain Trident submarines, and 3) bolstering U.S. deterrence without increasing the number of nuclear weapons.[30]
The B61-13 bomb is a useful addition to the U.S. capability but is less capable than the B83 bomb against very hard and very deeply buried facilities—including the ones that President Putin depends on to keep himself alive in a nuclear war.[31]
The Trident life extension was an emergency measure to prevent a decline in U.S. capability due to a delay in the Columbia class ballistic missile replacement program.[32]
In August 2024, then-Acting Assistant Secretary of Defense Dr. Vipin Narang stated that the Biden Administration had ended its opposition to the nuclear SLCM program.[33] In reality, the Navy is continuing to slow-roll it. Its projected availability date is about 17 years after President Trump directed the program in the 2018 Nuclear Posture Review. Former Deputy Assistant Secretary of Defense Dr. Robert Soofer has stated, “We have a missile, a Tomahawk missile, that has been upgraded continuously to the Block V. It’s got the range that we need,” and, “I guarantee you that the labs can put a nuclear warhead on that.”[34]
Combining Nuclear and Conventional Strikes
The Biden Administration’s nuclear employment guidance states that:
While recognizing that nuclear weapons continue to provide unique deterrence effects that no other element of U.S. military power can replace, the Guidance places greater emphasis on the use of non-nuclear capabilities to support the nuclear deterrence mission, where feasible. Such integration allows the Joint Force to combine nuclear and non-nuclear capabilities in complementary ways that leverage the individual characteristics of diverse forces.[35]
Conventional weapons cannot substitute for nuclear weapons in a combined war plan because: 1) there is a gigantic difference in lethality between nuclear and conventional weapons, which means that vast numbers of expensive conventional missiles would have to be procured; 2) the conventional systems would have to be given nuclear and electromagnetic pulse hardening which the Electromagnetic Pulse Commission determined to be impractical for all conventional munitions because of the cost;[36] 3) because of the threat of GPS jamming and other forms of GPS denial, dependence on GPS guidance would be very risky;[37] 4) thousands of expensive conventional weapons would have to be withheld from the conventional war plans and somehow maintained in a survivable configuration (probably financially impossible) to have a significant deterrent impact against nuclear weapons first use; 5) since conventional earth penetrators cannot generally destroy targets any deeper than they can penetrate,[38] which is limited, conventional weapons generally have little effect against very hard and very deeply buried targets, and 6) the effectiveness of the conventional strikes would be limited as likely would be their deterrent effect.
It is noteworthy that during the recent Eisenhower carrier strike group deployment to the Middle East it reportedly launched 135 Tomahawk Land Attack Missiles against Houthi terrorist targets and the carrier’s aircraft dropped 420 air-to-ground weapons.[39] Despite these attacks, the Houthi terrorists were able to continue their missile attacks.[40]
Protracted conventional strikes of the type conducted in a conventional conflict are not practical if an adversary is using nuclear weapons against U.S. forces and the U.S. adversaries know this. The U.S. inventory of precision conventional weapons is inadequate. Indeed, less than three weeks after the nuclear employment guidance had been made public, White House National Security Advisor Jake Sullivan stated that U.S. munitions would be exhausted in a China conflict “very rapidly.”[41] Hence, the threat of conventional attacks is unlikely to have any significant deterrent effect against nuclear escalation.
The cost of conventional capabilities is high. The platforms that carry and deploy the conventional missiles (bombers, strike fighters, surface ships and submarines) are much more expensive than the missiles themselves. For example, the cost of a Tomahawk Block 5 missile is reportedly $1,890,000 per round.[42] To increase the capacity of U.S. conventional forces to launch non-nuclear missiles as an intended substitute for one-to-three nuclear missiles after a nuclear attack on the United States and its allies would cost billions. One-to-three nuclear SLCMs would require no additional ships to deploy them and could accomplish the same attack and do it more effectively.
Clearly, President Biden had no intention of increasing defense spending to fund a serious effort to substitute conventional for nuclear strike. Moreover, the seriously eroded U.S. military production base probably cannot support the increased reliance on conventional weapons that the Biden nuclear employment guidance report pretends to direct. In reality, the Biden guidance will be all but ignored by the military because it is economically prohibitive. Hence, the supposed enhanced reliance on conventional weapons is apparently just a political fig leaf.
Missing Elements in the Nuclear Employment Guidance
There are missing elements in the Biden Administration’s nuclear employment guidance that should be restored even on an interim basis. A good starting point would be elements from the Reagan Administration’s Nuclear Employment Guidance. These include:
The exact Reagan language would need updating because it assumes capabilities that no longer exist (e.g., dual capability—combining nuclear and conventional warheads— has been nearly eliminated.) However, the concepts that underlie the Reagan guidance are still generally relevant.
Current U.S. nuclear forces cannot possibly win a nuclear war against a peer competitor much less two. However, U.S. nuclear employment guidance should not reinforce the current “no win” warfare mentality that exists in Washington (and adversary perceptions of it) which is resulting in defeat after defeat. U.S. adversaries cannot ignore what it says. As Admiral Richard and Robert Peters of the Heritage Foundation have pointed out, “Decisive victory ultimately deters a future war by changing the conditions that allowed a revisionist power to pursue conflict in the first place….In almost all cases, decisive victory takes the form of a new, better status quo post bellum that is based on a new power and political relationship between the victor and the vanquished.”[44]
The Biden nuclear employment guidance report does not even mention dealing with chemical or biological weapons threats and other catastrophic threats. The need to deter these threats was a major element in the 2020 Trump nuclear employment guidance report.[45]
The concept of a secure nuclear reserve force seems to have fallen out of U.S. planning. Yet, it is a key element in dealing with multiple nuclear-armed adversaries.
The probability that nuclear attacks against the United States will be conducted consistent with the law of armed conflict is almost certainly zero. There is a fundamental right under international law of “belligerent reprisal.” Indeed, “Belligerent reprisals have been employed on the battlefield for centuries and are one of the few available sanctions of the laws of war.”[46] The nuclear-armed dictators must be made to believe that there will be “hell to pay” if they launch high-yield nuclear attacks against American cities with genocidal intent.
The Russian Reaction to the New Nuclear Employment Guidance
The Russians appear to be unimpressed by the Biden Administration’s nuclear weapons employment guidance report. Russian state media didn’t even bother to attack it.
The Biden Administration’s Employment Guidance as a Constraint On President Trump
Mount and Kristensen state that, “When Donald Trump again takes custody of the nuclear codes in January, he will find no new guardrails on his ability to order use of U.S. nuclear weapons.”[47] While this appears in part to be a political attack on President Trump, he can sweep away any or all Biden executive orders on day one of his new Administration.
Suggested Near-Term Decisions on Nuclear Deterrence
In light of the multiple serious crisis situations the United States now faces, the following actions should be taken:
Initiate a comprehensive Nuclear Posture Review. Just the increase in Chinese nuclear capability justifies this.
[1] “Biden’s Secret Nuclear Weapons Strategy: Everything We Know About New Plan,” Newsweek, August 20, 2024, available at https://www.newsweek.com/bidens-secret-nuclear-weapons-strategy-everything-we-know-about-new-plan-1942076.
[2] Department of Defense, “Report on the Nuclear Employment Strategy of the United States,” Department of Defense, November 2024, p. 4, available at https://media.defense.gov/2024/Nov/15/2003584623/-1/-1/1/REPORT-ON-THE-NUCLEAR-EMPLOYMENT-STRATEGY-OF-THE-UNITED-STATES.PDF.
[3] Department of Defense, “DOD Sends Report to Congress on the Nuclear Weapons Employment Strategy of the United States,” Department of Defense, November 15, 2024, available at https://www.defense.gov/News/Releases/Release/Article/3966543/dod-sends-report-to-congress-on-the-nuclear-weapons-employment-strategy-of-the/.
[4] Michael R. Gordon, “U.S. Must Be Prepared to Expand Nuclear-Weapons Force, Biden Officials Say,” The Wall Street Journal, November 15, 2024, available at https://www.wsj.com/politics/national-security/u-s-must-be-prepared-to-expand-nuclear-weapons-force-biden-officials-say-3f317fc9.
[5] “Report on the Nuclear Employment Strategy of the United States,” 2024, op. cit., p. 3.
[6] Ibid., p. 2.
[7] Ibid., p. 1.
[8] Mark B. Schneider, “The October 2023 Strategic Commission Report and U.S. Nuclear Weapons Requirements,” Information Series, No. 568 (Fairfax, VA: National Institute Press, December 1, 2023), pp. viii, 34, 35, 43, 45, 46. 48, available at https://nipp.org/information_series/mark-b-schneider-the-october-2023-strategic-commission-report-and-u-s-nuclear-weapons-requirements-no-568-december-1-2023/.
[9] Department of Defense, Nuclear Posture Review Report, Department of Defense, April 2010, available at https://dod.defense.gov/portals/1/features/defensereviews/npr/2010_nuclear_posture_review_report.pdf.
[10] Mark B. Schneider, “Biden’s NPR: Assured Survival for Vladimir Putin,” Real Clear Defense, April 21, 2022, available at https://www.realcleardefense.com/2022/04/21/bidens_npr_assured_survival_for_vladimir_putin_828255.html.
[11] Schneider, “The October 2023 Strategic Commission Report and U.S. Nuclear Weapons Requirements,” op. cit.
[12] Adam Mount and Hans Kristensen, “Biden Nuclear Weapons Employment Guidance Leaves Nuclear Decisions to Trump,” Federation of American Scientists, December 5, 2024, available at https://fas.org/publication/biden-nuclear-weapons-employment-guidance-leaves-nuclear-decisions-to-trump/.
[13] Ibid.
[14] Loc. cit.
[15] Admiral Charles Richard, USN (Ret.) and Robert Peters, “Escalation: A Tool to Be Considered, Not Dismissed,” Information Series, No. 600 (Fairfax, VA: National Institute Press, October 2, 2024), available at https://nipp.org/information_series/admiral-charles-richard-usn-ret-and-robert-peters-escalation-a-tool-to-be-considered-not-dismissed-no-600-october-2-2024/.
[16] Department of Defense, “Report on the Nuclear Employment Strategy of the United States—2020,” Department of Defense, November 30, 2020, available at https://www.esd.whs.mil/Portals/54/Documents/FOID/Reading%20Room/NCB/21-F-0591_2020_Report_of_the_Nuclear_Employement_Strategy_of_the_United_States.pdf.
[17] “Report on the Nuclear Employment Strategy of the United States,” 2024, op. cit., p. 2.
[18] Jan Hanchett, “White House: Our Attempts at Keeping Iran from Getting Nukes Through Diplomacy ‘Didn’t Work’,” Breitbart.com, December 14, 2024, available at https://www.breitbart.com/clips/2024/12/14/white-house-our-attempts-at-keeping-iran-from-getting-nukes-through-diplomacy-didnt-work/.
[19] “‘In 24 Hours, Nukes…’: Iran’s Shocking Nuclear Announcement After Russia’s Warning,” The Times of India, November 19, 2024, available at https://timesofindia.indiatimes.com/videos/international/in-24-hours-nukes-irans-shocking-nuclear-announcement-after-russias-warning/videoshow/115458978.cms.
[20] “Putin Ally Issues Nuclear Warning to NATO,” Newsweek, September 27, 2024, available at https://www.newsweek.com/putin-ally-nuclear-warning-nato-lukashenko-belarus-nato-1960339.: “Belarusian missile crews practice operation of Iskander missiles carrying special warheads,” TASS, August 25, 2023, available at https://tass.com/defense/1665627.; “Russia, Belarus practice readying tactical nuclear forces and capabilities in joint drills,” TASS, June 13, 2024, available at https://tass.com/defense/1802803; Mark B. Schneider, “The Russian Non-Strategic (Tactical) Nuclear Exercise,” Real Clear Defense, September 17, 2024, available at https://www.realcleardefense.com/articles/2024/09/17/the_russian_non-strategic_tactical_nuclear_exercise_1058803.html; Jack Detsch, “Russia’s Nuclear Weapons Are Now in Belarus, Foreign Policy, March 14, 2024, available at https://foreignpolicy.com/2024/03/14/russia-nuclear-weapons-belarus-putin/.
[21] “Russia ready to deploy Oreshnik in Belarus in 2025 — Putin,” TASS, December 6, 2024, available at https://tass.com/politics/1883517.
[22] Department of Defense, “Deputy Pentagon Press Secretary Sabrina Singh Holds a Press Briefing,” Department of Defense, November 21, 2024, available at https://www.defense.gov/News/Transcripts/Transcript/Article/3975265/deputy-pentagon-press-secretary-sabrina-singh-holds-a-press-briefing/.
[23] “Meeting with the Defence Ministry leadership, representatives of the military-industrial complex and missile system developers,” Kremlin.ru, November 22, 2024, available at http://en.kremlin.ru/events/president/news/75623.
[24] Madelyn Creedon and Jon Kyl, et al., Congressional Commission on the Strategic Posture of the United States, America’s Strategic Posture, The Final Report of the Congressional Commission on the Strategic Posture of the United States, Institute for Defense Analysis, 2023, p. 84, available at https://www.ida.org/-/media/feature/publications/a/am/americas-strategic -posture/strategic-posture-commission-report.ashx.
[25] Ibid., p. 109.
[26] Pranay Vaddi, “Adapting the U.S. Approach to Arms Control and Nonproliferation to a New Era,” Arms Control Association, June 7, 2024, available at https://www.armscontrol.org/2024AnnualMeeting/Pranay-Vaddi-remarks.
[27] “Report on the Nuclear Employment Strategy of the United States,” 2024, op. cit.
[28] U.S. Department of State, Office of the Spokesperson, “Russian Noncompliance with and Invalid Suspension of the New START Treaty,” Fact Sheet, U.S. Department of State, June 1, 2023, available at https://www.state.gov/russian-noncompliance-with-and-invalid-suspension-of-the-new-start-treaty/.
[29] U.S. Department of State, “Report to Congress on Implementation of the New START Treaty Pursuant to paragraph (a)(10) of the Senate’s Resolution of Advice and Consent to Ratification of the New START Treaty (Treaty Doc. 111-5) NEW START TREATY ANNUAL IMPLEMENTATION REPORT,” U.S. Department of State, 2023, p. 5, available at https://www.state.gov/wp-content/uploads/2023/01/2022-New-START-Implementation-Report.pdf.
[30] Vaddi, “Adapting the U.S. Approach to Arms Control and Nonproliferation to a New Era,” op. cit. p. 5.
[31] Mark B. Schneider, “Putin’s New Assured Survival Nuclear Bunker,” Real Clear Defense, December 1, 2020, available at https://www.realcleardefense.com/articles/2020/12/01/putins_new_assured_survival_nuclear_bunker_651424.html.
[32] Creedon and Kyl, et al., America’s Strategic Posture, The Final Report of the Congressional Commission on the Strategic Posture of the United States, op. cit., p. 44.
[33] Remarks by Acting Assistant Secretary of Defense for Space Policy Dr. Vipin Narang at CSIS,” Department of Defense, August 1, 2024, available at https://www.defense.gov/News/Speeches/Speech/Article/3858311/nuclear-threats-and-the-role-of-allies-remarks-by-acting-assistant-secretary-of/.
[34] Sydney J. Freedberg Jr. “Sub-launched nuclear cruise missile will need ‘an entirely new industrial base,’ warns Navy admiral, Breaking Defense,” Breaking Defense, November 15, 2024, available at https://breakingdefense.com/2024/11/sub-launched-nuclear-cruise-missile-will-need-an-entirely-new-industrial-base-warns-navy-admiral/.
[35] “Report on the Nuclear Employment Strategy of the United States,” 2024, op. cit., p. 3.
[36] Dr. John S. Foster, Jr. et al., Report of the Commission to Assess the Threat to the United States from Electromagnetic Pulse (EMP) Attack,” Volume 1: Executive Report, 2004, p. 47, available at https://www.empcommission.org/docs/empc_exec_rpt.pdf.
[37] General Michael Hostage III, Commander, USAF Air Combat Command, “Future of the Combat Air Force,” AFA – Air & Space Conference and Technology Exposition, September 16, 2014, available at https://www.af.mil/Portals/1/documents/af%20events/Speeches/16SEP2014-Gen-Michael-Hostage-Future-of-the-Combat-AF-AFA-Conference.pdf.
[38] “Summary,” of Effects of Nuclear and Earth Penetrator and Other Weapons, National Academies of Sciences, Engineering, and Medicine (Washington, D.C.: The National Academies Press, 2005), available at https://doi.org/10.17226/11282.
[39] Usman Ansari, “The Most Intense Sea Combat Since WW2,” in Ian Ballantyne ed., Guide to the US Navy 2025, (London: Sundial Magazines Ltd., September 13, 2024), p. 66.
[40] “Houthi Ballistic Missiles Impact Israel-linked Anadolu S Ship In Red Sea ‘Accurate & Direct Hit’,” Times of India, November 20, 2024, available at https://timesofindia.indiatimes.com/videos/international/houthi-ballistic-missiles-impact-israel-linked-anadolu-s-ship-in-red-sea-accurate-direct-hit/videoshow/115475039.cms.
[41] Bill Gertz, “Pentagon alert: U.S. runs out of missiles in a ‘matter of days’ in China war, can’t match production,” The Washington Times, December 5, 2024, available at https://www.washingtontimes.com/news/2024/dec/5/congress-u-defense-industry-unable-supply-weapons-/.
[42] Tyler Rogoway, “What The Navy’s Ship-Launched Missiles Actually Cost,” The War Zone, May 21, 2024, available https://www.twz.com/sea/what-the-navys-ship-launched-missiles-actually-cost.
[43] Ronald Reagan, “NUCLEAR WEAPONS EMPLOYMENT POLICY,” NAT10NAL SECURITY DECISION DIRECTIVE NUMBER 13, The White House, no date, available at https://www.reaganlibrary.gov/public/archives/reference/scanned-nsdds/nsdd13.pdf.
[44] Admiral Charles Richard, USN (Ret.) and Robert Peters, “On Victory and the Search for a Status Quo Ante Bellum,” Information Series, No. 603 (Fairfax, VA: National Institute Press, October 24, 2024), available at https://nipp.org/information_series/admiral-charles-richard-usn-ret-and-robert-peters-on-victory-and-the-search-for-a-status-quo-ante-bellum-no-603-october-24-2024/.
[45] “Report on the Nuclear Employment Strategy of the United States—2020,” op. cit., p. 8.
[46] Shane Darcy, “The Evolution of the Law of Belligerent Reprisals,” Military Law Review, Vol. 175, 2003, pp. 184-251.
[47] Mount and Kristensen, “Biden Nuclear Weapons Employment Guidance Leaves Nuclear Decisions to Trump,” op. cit.
[48] Ibid.: “The Potential Costs of Expanding U.S. Strategic Nuclear Forces If the New START Treaty Expires,” Congressional Budget Office, August 2020, available at https://www.cbo.gov/publication/56524.
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