Critical Infrastructure Protection
Improving Information Sharing with Infrastructure Sectors Gao ID: GAO-04-780 July 9, 2004Critical infrastructure protection (CIP) activities called for in federal policy and law are intended to enhance the security of the public and private infrastructures that are essential to our nation's security, economic security, and public health and safety. Effective information-sharing partnerships between industry sectors and government can contribute to CIP efforts. Federal policy has encouraged the voluntary creation of information sharing and analysis centers (ISAC) to facilitate infrastructure sector participation in CIP information sharing efforts. GAO was asked to identify actions that the Department of Homeland Security (DHS) could take to improve the effectiveness of CIP information-sharing efforts.
Federal awareness of the importance of securing the nation's critical infrastructures--and the federal government's strategy to encourage cooperative efforts among state and local governments and the private sector to protect these infrastructures--have been evolving since the mid-1990s. Federal policy continues to emphasize the importance of the ISACs and their information-sharing functions. In addition, federal policy established specific responsibilities for DHS and other federal agencies involved with the CIP sectors. The ISACs have identified challenges requiring further federal action, including building trusted relationships; developing processes to facilitate information sharing; overcoming barriers to information sharing; clarifying the roles and responsibilities of the various government and private-sector entities that are involved in protecting critical infrastructures; and funding ISAC operations and activities. A lthough DHS has taken a number of actions to implement the public/private partnership called for by federal CIP policy, it has not yet developed a plan that describes how it will carry out its information-sharing responsibilities and relationships. Such a plan could encourage improved information sharing among the ISACs, other CIP entities, and the department by clarifying the roles and responsibilities of all the entities involved and clearly articulating actions to address the challenges that remain. DHS officials indicated that they intend to develop an information-sharing plan, but no specific time frame for completing the plan has been established. The department also lacks policies and procedures to ensure effective coordination and sharing of ISAC-provided information among the appropriate components within the department. Developing policies and procedures would help ensure that information is effectively and efficiently shared among its components and with other government and private-sector CIP entities.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-04-780, Critical Infrastructure Protection: Improving Information Sharing with Infrastructure Sectors
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
July 2004:
CRITICAL INFRASTRUCTURE PROTECTION:
Improving Information Sharing with Infrastructure Sectors:
GAO-04-780:
GAO Highlights:
Highlights of GAO-04-780, a report to congressional requesters
Why GAO Did This Study:
Critical infrastructure protection (CIP) activities called for in
federal policy and law are intended to enhance the security of the
public and private infrastructures that are essential to our nation‘s
security, economic security, and public health and safety. Effective
information-sharing partnerships between industry sectors and
government can contribute to CIP efforts.
Federal policy has encouraged the voluntary creation of information
sharing and analysis centers (ISAC) to facilitate infrastructure sector
participation in CIP information sharing efforts. GAO was asked to
identify actions that the Department of Homeland Security (DHS) could
take to improve the effectiveness of CIP information-sharing efforts.
What GAO Found:
Federal awareness of the importance of securing the nation‘s critical
infrastructures”and the federal government‘s strategy to encourage
cooperative efforts among state and local governments and the private
sector to protect these infrastructures”have been evolving since the
mid-1990s. Federal policy continues to emphasize the importance of the
ISACs and their information-sharing functions. In addition, federal
policy established specific responsibilities for DHS and other federal
agencies involved with the CIP sectors. The ISACs have identified
challenges requiring further federal action, including building trusted
relationships; developing processes to facilitate information sharing;
overcoming barriers to information sharing; clarifying the roles and
responsibilities of the various government and private-sector entities
that are involved in protecting critical infrastructures; and funding
ISAC operations and activities.
Although DHS has taken a number of actions to implement the
public/private partnership called for by federal CIP policy, it has not
yet developed a plan that describes how it will carry out its
information-sharing responsibilities and relationships. Such a plan
could encourage improved information sharing among the ISACs, other CIP
entities, and the department by clarifying the roles and
responsibilities of all the entities involved and clearly articulating
actions to address the challenges that remain. DHS officials indicated
that they intend to develop an information-sharing plan, but no
specific time frame for completing the plan has been established.
The department also lacks policies and procedures to ensure effective
coordination and sharing of ISAC-provided information among the
appropriate components within the department. Developing policies and
procedures would help ensure that information is effectively and
efficiently shared among its components and with other government and
private-sector CIP entities.
What GAO Recommends:
GAO recommends that the Secretary of Homeland Security direct officials
within DHS to (1) proceed with the development of an
information-sharing plan that describes the roles and responsibilities
of DHS, the ISACs, and other entities and (2) establish appropriate
department policies and procedures for interactions with other CIP
entities and for coordination and information sharing among DHS
components. DHS commented on a draft of this report and generally
agreed with our findings and recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-04-780.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert F. Dacey at 202-
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[End of section]
Contents:
Letter:
Results in Brief:
Background:
Further DHS Actions Could Enhance Information Sharing:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendixes:
Appendix I: GAO's April 21, 2004, Testimony:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: Comments from the Department of Health and Human
Services:
Appendix IV: Comments from the Department of the Treasury:
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Staff Acknowledgments:
Tables:
Table 1: Critical Infrastructure Sectors Identified by Federal Policy:
Table 2: ISACs by Sector:
Abbreviations:
CIP: critical infrastructure protection:
DHS: Department of Homeland Security:
HHS: Department of Health and Human Services:
HSPD: Homeland Security Presidential Directive:
IAIP: Information Analysis and Infrastructure Protection:
ISAC: information sharing and analysis center:
TSA: Transportation Security Administration:
Letter July 9, 2004:
The Honorable Mac Thornberry:
Chairman, Subcommittee on Cybersecurity, Science, and Research and
Development:
Select Committee on Homeland Security:
House of Representatives:
The Honorable Zoe Lofgren
Ranking Member Subcommittee on Cybersecurity, Science, and Research
and Development:
Select Committee on Homeland Security:
House of Representatives:
The Honorable Dave Camp:
Chairman, Subcommittee on Infrastructure and Border Security:
Select Committee on Homeland Security:
House of Representatives:
The Honorable Loretta Sanchez:
Ranking Member, Subcommittee on Infrastructure and Border Security:
Select Committee on Homeland Security:
House of Representatives:
Federal policy and law, including the Homeland Security Act of
2002,[Footnote 1] call for critical infrastructure protection (CIP)
activities intended to enhance the security of the cyber and physical,
public, and private infrastructures that are essential to national
security, national economic security, or national public health and
safety. Federal policy, evolving since the mid-1990s, has encouraged
the voluntary creation of information sharing and analysis centers
(ISAC) to facilitate the private sector's participation in CIP by
serving as mechanisms for gathering and analyzing information and
sharing it among the infrastructure sectors and between the private
sector and government. In addition, federal policy established specific
responsibilities for the Department of Homeland Security (DHS) and
other federal agencies involved with the CIP infrastructure sectors,
including designation of sector-specific federal agencies for each
sector to coordinate CIP activities and sector coordinators from the
sectors to work with the sector-specific agencies.
In April, we testified before your subcommittees on the status of
private-sector ISACs and their efforts to help protect our nation's
critical infrastructures[Footnote 2] (see app.1). In brief, we reported
that:
* the current ISACs were established and developed based on the unique
characteristics and needs of their individual sectors;
* DHS and the sector-specific agencies have undertaken a number of
efforts to address the public/private partnership called for by federal
policy on critical infrastructure protection and to continue to develop
their relationships with the ISACs and with each other; and:
* a number of challenges to the ISACs' successful establishment,
operation, and partnership with DHS and other federal agencies remain,
some of which were described by the ISAC Council[Footnote 3] through a
series of white papers.
Subsequent to the April 2004 testimony, your staff requested that we
identify actions DHS could take to improve the effectiveness of CIP
information sharing efforts. To address this objective, we considered
evidence gathered to support our April 2004 testimony, including
analysis of information obtained from officials from ISAC
organizations, the ISAC Council, and sector-specific agencies. We
performed our work from November 2003 to May 2004, in accordance with
generally accepted government auditing standards.
Results in Brief:
DHS can take two key actions to improve the effectiveness of its
information-sharing efforts with the ISACs and others. First, a number
of challenges have been identified by the ISAC community that could be
addressed with the development of an information-sharing plan that,
among other things, defines the roles and responsibilities of the
various stakeholders and establishes criteria for providing the
appropriate incentives to address the challenges. In addition, DHS's
ability to gather, analyze, and disseminate information could be
improved by developing information sharing-related policies and
procedures for its components. We are making recommendations to DHS to
proceed with the development of an information sharing plan and to
establish appropriate policies and procedures for interacting with
ISACs, sector coordinators, and sector-specific agencies, and for
coordination and information sharing within DHS components.
DHS and the Departments of Health and Human Services (HHS) and the
Treasury provided written comments on a draft of this report (see app.
II, III, and IV, respectively). In its comments, a representative from
DHS's Office of the Chief Financial Officer stated that the department
generally agreed with our findings and the recommendations. We also
received technical comments from the Environmental Protection Agency,
which have been incorporated into this report, as appropriate. The
Departments of Agriculture and Energy reviewed a draft of this report
and responded by stating that they had no comments.
Background:
Information sharing is an integral part of the federal government's CIP
efforts. As discussed in our April testimony, a number of ISACs have
been established to meet the information-sharing needs of their
respective sectors, and the federal government has undertaken steps to
improve CIP information sharing. Yet sector representatives have
identified a number of challenges to effective information sharing.
Federal CIP Policy Emphasizes Information Sharing:
Federal law and policy emphasize the importance of information sharing
to the successful protection of our nation's critical infrastructures.
The Homeland Security Act of 2002 established DHS and made the
department's Information Analysis and Infrastructure Protection (IAIP)
Directorate responsible for CIP functions with a lead role for
information sharing within DHS and the federal government.[Footnote 4]
IAIP's responsibilities include:
* accessing, receiving, and analyzing law enforcement information,
intelligence information, and other threat and incident information
from respective agencies of federal, state, and local governments and
the private sector;
* combining and analyzing such information to identify and assess the
nature and scope of terrorist threats; and:
* disseminating, as appropriate, information analyzed by DHS, within
the department, to other federal agencies, state and local government
agencies, and private-sector entities.
As also required by the Homeland Security Act, IAIP is responsible for
(1) developing a comprehensive national plan for securing the key
resources and critical infrastructure of the United States and
(2) recommending measures to protect the key resources and critical
infrastructure of the United States in coordination with other federal
agencies and in cooperation with state and local government agencies
and authorities, the private sector, and other entities.
Current CIP policy, described in Homeland Security Presidential
Directive 7 (HSPD-7), defines responsibilities for DHS, sector-specific
agencies, and other departments and agencies. It instructs federal
departments and agencies to identify, prioritize, and coordinate the
protection of critical infrastructure to prevent, deter, and mitigate
the effects of attacks. The Secretary of Homeland Security is assigned
several responsibilities, including establishing uniform policies,
approaches, guidelines, and methodologies for integrating federal
infrastructure protection and risk management activities within and
across sectors. To ensure the coverage of critical sectors, HSPD-7
designated sector specific agencies for the critical infrastructure
sectors identified. These agencies are responsible for infrastructure
protection activities in their assigned sectors, which include
coordinating and collaborating with relevant federal agencies, state
and local governments, and the private sector to carry out their
responsibilities and facilitating the sharing of information about
physical and cyber threats, vulnerabilities, incidents, potential
protective measures, and best practices. Further, the sector-specific
agencies are to continue to encourage the development of information-
sharing and analysis mechanisms and to support sector-coordinating
mechanisms. Table 1 identifies the infrastructure sectors specified in
federal policy and the related sector-specific agencies.
Table 1: Critical Infrastructure Sectors Identified by Federal Policy:
Sector: Agriculture;
Description: Provides for the fundamental need for food. The
infrastructure includes supply chains for feed and crop production;
Sector-specific agency: Department of Agriculture and Department of
Health and Human Services.
Sector: Banking and finance;
Description: Provides the financial infrastructure of the nation. This
sector consists of commercial banks, insurance companies, mutual funds,
government-sponsored enterprises, pension funds, and other financial
institutions that carry out transactions including clearing and
settlement;
Sector-specific agency: Department of the Treasury.
Sector: Chemicals and hazardous materials;
Description: Transforms natural raw materials into commonly used
products benefiting society's health, safety, and productivity. The
chemical industry represents a $450 billion enterprise and produces
more than 70,000 products that are essential to automobiles,
pharmaceuticals, food supply, electronics, water treatment, health,
construction, and other necessities;
Sector- specific agency: Department of Homeland Security.
Sector: Defense industrial base;
Description: Supplies the military with the means to protect the nation
by producing weapons, aircraft, and ships and providing essential
services, including information technology and supply and maintenance;
Sector-specific agency: Department of Defense.
Sector: Emergency services;
Description: Saves lives and property from accidents and disaster.
This sector includes fire, rescue, emergency medical services, and law
enforcement organizations;
Sector-specific agency: Department of Homeland Security.
Sector: Energy;
Description: Provides the electric power used by all sectors, including
critical infrastructures, and the refining, storage, and distribution
of oil and gas. The sector is divided into electricity and oil and
natural gas;
Sector-specific agency: Department of Energy.
Sector: Food;
Description: Carries out the postharvesting of the food supply,
including processing and retail sales;
Sector-specific agency: Department of Agriculture and Department of
Health and Human Services.
Sector: Government;
Description: Ensures national security and freedom and administers key
public functions;
Sector-specific agency: Department of Homeland Security.
Sector: Information technology and telecommunications;
Description: Provides communications and processes to meet the needs
of businesses and government;
Sector-specific agency: Department of Homeland Security.
Sector: Postal and shipping;
Description: Delivers private and commercial letters, packages, and
bulk assets. The U.S. Postal Service and other carriers provide the
services of this sector;
Sector- specific agency: Department of Homeland Security.
Sector: Public health and healthcare;
Description: Mitigates the risk of disasters and attacks and also
provides recovery assistance if an attack occurs. The sector consists
of health departments, clinics, and hospitals;
Sector-specific agency: Department of Health and Human Services.
Sector: Transportation;
Description: Enables movement of people and assets that are vital to
our economy, mobility, and security with the use of aviation, ships,
rail, pipelines, highways, trucks, buses, and mass transit;
Sector-specific agency: Department of Homeland Security.
Sector: Drinking water and water treatment systems;
Description: Provides drinking water and wastewater treatment through
approximately 170,000 public water systems. These systems depend on
reservoirs, dams, wells, treatment facilities, pumping stations, and
transmission lines;
Sector-specific agency: Environmental Protection Agency.
Source: GAO analysis of the President's National Strategy documents
and HSPD-7.
[End of table]
Private Sector ISACs Established:
As more fully discussed in our April testimony, ISACs were voluntarily
created to provide an information sharing and analysis capability to
support their members' efforts to mitigate risk and effectively respond
to adverse events, including cyber, physical, and natural events. ISACs
have been established within most of the critical infrastructure
sectors identified in federal policy, including those for banking and
finance, chemicals and hazardous materials, drinking water and water
treatment systems, emergency services, energy, food, government,
information technology and telecommunications, and transportation.
ISACs have also been established for other industry sectors, including
real estate and research and education networking. Further, the
agriculture and healthcare infrastructure sectors are continuing their
efforts to establish information sharing mechanisms. Table 2 identifies
the sectors with ISACs.
Table 2: ISACs by Sector:
Sector: Banking and Finance;
ISAC: Financial Services;
Established: October 1999.
Sector: Chemicals and Hazardous Materials;
ISAC: Chemical;
Established: April 2002.
Sector: Emergency Services;
ISAC: Emergency Fire;
Established: October 2000.
Sector: Energy;
ISAC: Electric;
Established: October 2000.
Sector: Energy;
ISAC: Energy;
Established: November 2001.
Sector: Food;
ISAC: Food;
Established: February 2002.
Sector: Government;
ISAC: Multi-State;
Established: January 2003.
Sector: Information Technology and Telecommunications;
ISAC: IT;
Established: December 2000.
Sector: Information Technology and Telecommunications;
ISAC: Sector: Telecom;
Established: Sector: January 2000.
Sector: Information Technology and Telecommunications;
ISAC: Research and Education Networking;
Established: February 2003.
Sector: Transportation;
ISAC: Public Transit;
Established: January 2003.
Sector: Transportation;
ISAC: Sector: Surface Transportation;
Established: Sector: May 2002.
Sector: Transportation;
ISAC: Water and Water Treatment Systems: Highway;
Established: Water and Water Treatment Systems: March 2003.
Sector: Drinking Water and Water Treatment Systems;
ISAC: Water;
Established: December 2002.
Sector: Other;
ISAC: Real Estate;
Established: April 2003.
Source: GAO.
[End of table]
Although their overall missions are similar, the current ISACs were
established and developed based on the unique characteristics and needs
of their individual sectors. They operate under different management
and operational structures and, among other things, have different
business models and funding mechanisms. For example, most are managed
or operated as private entities, and some, such as the Water and
Chemical ISACs, are part of associations that represent their sectors.
Others have partnered with government agencies, such as the
Telecommunications ISAC, which is a government/industry operational and
collaborative body sponsored by DHS's National Communications Systems/
National Coordinating Center for Telecommunications. Different funding
mechanisms used by the ISACs include fee-for-service, association
sponsorship, grants, contracts, and/or voluntary or in-kind operations
by ISAC participants. ISACs that use fee-for-service funding include
the Financial Services, Information Technology, and Water ISACs, which
offer tiered memberships with fees based on the level of service
provided.
Federal Actions Taken to Address Information Sharing Challenges:
Sector-specific agencies are to collaborate with the private sector and
continue to encourage the development of information-sharing and
analysis mechanisms. In addition, sector-specific agencies are to
facilitate the sharing of information about physical and cyber threats,
vulnerabilities, incidents, potential protective measures, and best
practices. Some sector-specific agencies have taken steps to help the
ISACs to increase their memberships and breadth of impact within their
respective sectors and to improve their analytical and communications
capabilities. As we discussed more specifically in our April testimony,
sector-specific agencies, among other things, have:
* Provided funds to enhance ISAC capabilities and expand membership.
For example, the Environmental Protection Agency is the sector-specific
agency for the water sector. It reported that for fiscal year 2004, it
had issued in March 2004 a $2 million grant to the Water ISAC to
enhance its capabilities--to fund 24x7 operations and to increase and
support ISAC membership. In addition, the Department of the Treasury
entered into a $2 million contract with the Financial Services ISAC for
developing the "next generation" Financial Services ISAC by enhancing
the ISAC's capabilities and develop performance metrics.
* Sponsored outreach briefings to address why the private sector needs
to partner with the federal government. For example, the Federal
Deposit Insurance Corporation, Financial and Banking Information
Infrastructure Committee, and the Financial Services Sector
Coordinating Council are sponsoring regional outreach briefings that
address why the private sector needs to partner with the federal
government to improve its security.[Footnote 5] In addition, in
December 2003, DHS hosted a 2-day CIP retreat with ISAC
representatives, sector coordinators, and high-level DHS and White
House Homeland Security Council officials. Participants discussed the
needs, roles, and responsibilities of public-and private-sector
entities related to information sharing and analysis, incident
coordination and response activities, critical infrastructure
information requests, and level of DHS funding.
* Assisted infrastructure sectors in organizing sector-wide activities
and establishing ISACs. For example, last summer, DHS, the Department
of Agriculture, and HHS' Food and Drug Administration initiated efforts
to organize the agriculture and food critical infrastructure sectors to
raise awareness, coordinate, and improve security efforts. In addition
to the efforts listed above, DHS officials stated that they are
providing funding for tabletop exercises, including for the Financial
Services, Telecommunications, and Electricity Sector ISACs.
Challenges to Effective Information Sharing Remain:
The ISACs and the series of ISAC Council white papers confirmed that a
number of challenges remain to the successful establishment and
operation of ISACs and their partnership with DHS and the other sector-
specific agencies. The ISACs and the ISAC Council identified challenges
that would require federal action. Some of the more significant
challenges identified were the following:
* Government agencies and the ISACs need to build trusted relationships
between them to facilitate information sharing. In some cases,
establishing such relationships may be difficult because sector-
specific agencies may also have a regulatory role.
* The federal government and the private sector should share
information on incidents, threats, and vulnerabilities. Most ISACs
reported that they believed they were providing appropriate information
to the government but, while noting improvements, they still had
concerns with the information being provided to them by DHS and/or
their sector-specific agencies. These concerns included the limited
quantity of information and the need for more specific, timely, and
actionable information. In its recent white papers, the ISAC Council
also has identified a number of potential barriers to information
sharing between the private sector and the government. These included
the sensitivity of the information (such as law enforcement
information), legal limits on disclosure (such as Privacy Act
limitations on disclosure of personally identifiable information), and
contractual and business limits on how and when information is
disclosed (e.g., the Financial Services ISAC does not allow any
governmental or law enforcement access to its database). The Council
also emphasized that perhaps the greatest barriers to information
sharing stem from practical and business considerations in that,
although important, the benefits of sharing information are often
difficult to discern, while the risks and costs of sharing are direct
and foreseeable.
* The roles of the various government and private-sector entities
involved in protecting critical infrastructures must continue to be
identified and defined. In particular, officials for several ISACs
wanted a better definition of DHS's role with respect to them. The ISAC
Council also identified the need for DHS to establish the goals of its
directorates and the relationships of these directorates with the
private sector. The Council also wants clarification of the roles of
other federal agencies, state agencies, and other entities--such as the
National Infrastructure Advisory Council.
* Government funding is needed. Ten of the ISACs we contacted
emphasized the importance of government funding for purposes including
creating the ISAC, supporting operations, increasing membership,
developing metrics, and providing for additional capabilities.
* Private-sector analytical efforts should not be overlooked and must
be integrated into the federal processes for a more complete
understanding. The private sector understands its processes, assets,
and operations best and can be relied upon to provide the required
private-sector subject matter expertise.
Further DHS Actions Could Enhance Information Sharing:
DHS has taken a number of actions to implement the public/private
partnership called for by federal CIP policy. However, DHS has not yet
developed a plan for how it will carry out its information sharing
responsibilities, including efforts to address the challenges
identified by the ISACs and the ISAC Council. In addition, DHS has not
developed internal policies and procedures to help ensure effective
information sharing by the many entities within the department that
collect and analyze information that may impact the security of our
nation's critical infrastructure. It is essential for DHS to develop
this plan, along with internal policies and procedures, to establish
effective information-sharing relationships both within DHS and with
other federal agencies and infrastructure sectors.
DHS Has Not Developed an Overall Information Sharing Plan:
Although DHS has taken a number of actions to develop relationships
with the private sector and enhance information sharing capabilities,
it has not developed a plan that describes how it will carry out its
information-sharing responsibilities and/or how it will address the
many identified challenges that exist in building a public/private
information-sharing partnership. Development of a plan could improve
information sharing by clarifying roles and responsibilities and
clearly articulating actions to address the challenges that remain,
including consideration of appropriate incentives for nonfederal
entities to increase information sharing with the federal government,
increase sector participation, and/or perform other specific tasks to
protect the critical infrastructure.
In addition, soliciting input and feedback from the ISACs, sector
coordinators, and sector-specific agencies in developing the plan could
help DHS to ensure that the challenges identified by the ISACs and the
ISAC Council are appropriately considered.
According to DHS officials, the department intends to develop a plan
(referred to as a "roadmap") that documents the current information-
sharing relationships among DHS, the sectors and their ISACs, and other
agencies; goals for improving that information-sharing relationship;
and methods for measuring the progress in the improvement. According to
one official, the plan will define the roles and responsibilities of
DHS, the ISACs, and other entities, including a potential overlap of
ISAC-related responsibilities between IAIP and the Transportation
Security Administration (TSA). Further, the official indicated that, in
developing such a plan, DHS would consider issues raised by the ISACs
and the ISAC Council. This official indicated that a specific time
frame for completing the plan had not yet been established but that DHS
intends to develop a time frame this summer.
DHS Lacks Policies and Procedures to Guide Its Information-Sharing
Efforts:
DHS has established functions within the department to support the
ISACs and other CIP efforts. IAIP, as the DHS component directly
responsible for CIP activities, carries out many of these functions.
The Infrastructure Coordination Division within IAIP plays a key role
in coordinating with the ISACs concerning information sharing.
Nonetheless, ISACs may interact with multiple components of the
department. For example, the ISACs may discuss cyber issues with the
National Cyber Security Division and/or with the Homeland Security
Operations Center when reporting incidents.
Further, according to DHS officials, TSA, within the department's
Border and Transportation Security Directorate, is working with
organizations in the private sector to establish information-sharing
relationships. For example, Surface Transportation ISAC analysts stated
that they have a good working relationship with TSA, and TSA's
Operations Center has office space designated for them.
In addition, the Infrastructure Coordination Division is in the process
of staffing analysts who are responsible for working with each critical
infrastructure sector. The analysts would serve as the primary points
of contact within DHS for the sectors and would address information
sharing, coordination, infrastructure protection, and other issues
raised by the sectors.
According to a DHS official, the department does not intend to
establish a single point of contact for ISACs within the department.
Rather, the department plans to develop policies and procedures to
ensure effective coordination and sharing of ISAC-provided information
among the appropriate DHS components. At the time of our review, DHS
had not developed those policies and procedures and had no specific
time frame for their completion. Because of the many DHS components
potentially interacting with critical infrastructure sectors,
establishment of policies and procedures could help DHS ensure that
information is effectively and efficiently shared within the IAIP
Directorate and among DHS components, as well as with other federal
agencies and infrastructure sectors, by clarifying roles,
responsibilities, and processes.
Conclusions:
Although DHS has taken a number of actions to establish and improve
information sharing relationships among entities within the
infrastructure sectors and between the infrastructure sectors and the
federal government, a number of challenges remain that are barriers to
developing effective public-private partnerships. The ISACs and other
stakeholders, including sector-specific agencies and sector
coordinators, could benefit from an overall DHS strategy, as well as
specific guidance, that clearly describes their roles,
responsibilities, relationships, and expectations. In developing such a
strategy, it will also be important to consider input from all
stakeholders to help ensure that a comprehensive and trusted
information-sharing process is established. DHS has also not yet
developed the internal policies and procedures needed to ensure that
appropriate information sharing occurs within the department, which
could affect its overall ability to perform analysis and disseminate
critical information about incidents, vulnerabilities, or threats.
Recommendations for Executive Action:
To help improve the effectiveness of DHS's information-sharing efforts
with the ISACs and others, we recommend that the Secretary of Homeland
Security direct officials within the IAIP Directorate to take the
following two actions:
* Proceed with and establish milestones for the development of an
information-sharing plan that includes (1) a clear description of the
roles and responsibilities of DHS, the ISACs, the sector coordinators,
and the sector-specific agencies and (2) actions designed to address
information-sharing challenges. Efforts to develop this plan should
include soliciting feedback from the ISACs, sector coordinators, and
sector-specific agencies to help ensure that challenges identified by
the ISACs and the ISAC Council are appropriately considered in the
final plan.
* Considering the roles, responsibilities, and actions established in
the information-sharing plan, develop appropriate DHS policies and
procedures for interacting with ISACs, sector coordinators, and sector-
specific agencies and for coordination and information sharing within
the IAIP Directorate (such as the National Cyber Security Division and
Infrastructure Coordination Division) and other DHS components that may
interact with the ISACs, including TSA.
Agency Comments:
We received written comments on a draft of this report from DHS, HHS,
and the Department of the Treasury (see apps. II, III, and IV,
respectively). In DHS's response, a representative from DHS's Office of
the Chief Financial Officer stated that the report generally provides
an accurate analysis of the current sector ISAC landscape. In addition,
the director provided planned actions to address the recommendations
identified in this report. HHS's Acting Principal Deputy Inspector
General stated that the department had no comments. In Treasury's
response, the Under Secretary for Domestic Finance stated that the
department agreed with our findings. These departments also provided
technical comments, which were incorporated into the report, as
appropriate.
In addition, the Environmental Protection Agency provided separate
technical comments, which were incorporated into this report, as
appropriate. The Departments of Agriculture and Energy reviewed a draft
of this report and responded by stating that they had no comments.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to other interested congressional committees, the Secretary of Homeland
Security, and the heads of the agencies discussed in this report. We
also will make copies available to others upon request. In addition,
the report will be available at no charge on the GAO Web site at
http://www.gao.gov.
If you should have any questions about this report, please contact me
at (202) 512-3317 or Ben Ritt, Assistant Director, at (202) 512-6443.
We can also be reached by e-mail at daceyr@gao.gov and rittw@gao.gov
respectively. Key contributors to this report are listed in appendix V.
Signed by:
Robert F. Dacey
Director, Information Security Issues:
Appendixes:
Appendix I: GAO's April 21, 2004, Testimony:
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Testimony:
Before the Subcommittees on Cybersecurity, Science, and Research &
Development and Infrastructure and Border Security, Select Committee on
Homeland Security, House of Representatives:
United States General Accounting Office:
GAO:
For Release on Delivery Expected at 10:30 a.m. EDT:
Wednesday, April 21, 2004:
CRITICAL INFRASTRUCTURE PROTECTION:
Establishing Effective Information Sharing with Infrastructure
Sectors:
Statement of Robert F. Dacey
Director, Information Security Issues:
GAO-04-699T:
GAO Highlights:
Highlights of GAO-04-699T, testimony before the Subcommittees on
Cybersecurity, Science, and Research & Development and on
Infrastructure and Border Security, Select Committee on Homeland
Security, House of Representatives
Why GAO Did This Study:
Critical infrastructure protection (CIP) activities that are called for
in federal policy and law are intended to enhance the security of the
cyber and physical public and private infrastructures that are
essential to our nation‘s security, economic security, and public
health and safety. As our reliance on these infrastructures increases,
so do the potential threats and attacks that could disrupt critical
systems and operations. Effective information-sharing partnerships
between industry sectors and government can contribute to CIP efforts.
Federal policy has encouraged the voluntary creation of Information
Sharing and Analysis Centers (ISACs) to facilitate the private sector‘s
participation in CIP by serving as mechanisms for gathering and
analyzing information and sharing it among the infrastructure sectors
and between the private sector and government. This testimony discusses
the management and operational structures used by ISACs, federal
efforts to interact with and support the ISACs, and challenges to and
successful practices for ISACs‘ establishment, operation, and
partnerships with the federal government.
What GAO Found:
Federal awareness of the importance of securing the nation‘s critical
infrastructures”and the federal government‘s strategy to encourage
cooperative efforts among state and local governments and the private
sector to protect these infrastructures”have been evolving since the
mid-1990s. Federal policy continues to emphasize the importance of the
ISACs and their information-sharing functions. In addition, federal
policy established specific responsibilities for the Department of
Homeland Security (DHS) and other federal agencies involved with the
private sector in CIP. The ISACs themselves, although they have similar
missions, were developed to serve the unique needs of the sectors they
represent, and they operate under different business models and funding
mechanisms.
According to ISAC representatives and a council that represents many of
them, a number of challenges to their successful establishment,
operation, and partnership with DHS and other federal agencies remain.
These challenges include increasing the percentage of entities within
each sector that are members of its ISAC; building trusted
relationships and processes to facilitate information sharing;
overcoming barriers to information sharing, clarifying the roles and
responsibilities of the various government and private sector entities
that are involved in protecting critical infrastructures; and funding
ISAC operations and activities. According to a DHS official, these
issues are being considered, and the department is developing a plan
that will document the current information-sharing relationships among
DHS, the ISACs, and other agencies; goals for improving those
information-sharing relationships; and methods for measuring progress
toward these goals.
Information Sharing and Analysis Centers by Sector:
[See PDF for image]
[End of figure]
www.gao.gov/cgi-bin/getrpt?GAO-04-699T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert F. Dacey at
202-512-3317 or Daceyr@gao.gov
[End of section]
Messrs. Chairmen and Members of the Subcommittees:
I am pleased to be here today to discuss the status of private-sector
information sharing and analysis centers (ISACs) and their efforts to
help protect our nation's critical infrastructures. Critical
infrastructure protection (CIP) activities called for in federal policy
and law are intended to enhance the security of cyber and physical,
public and private infrastructures that are essential to national
security, national economic security, or national public health and
safety. Beginning with Presidential Decision Directive 63 (PDD 63),
issued in May 1998, federal policy has encouraged the voluntary
creation of ISACs to facilitate private-sector participation and serve
as mechanisms for gathering, analyzing, and appropriately sanitizing
and disseminating information to and from infrastructure sectors and
the federal government. Subsequent federal CIP policy, including
several national strategies, has continued to emphasize the importance
of the ISACs and their information-sharing functions.[Footnote 1]
Further, CIP policy has established specific responsibilities for the
Department of Homeland Security (DHS) and other federal agencies with
respect to public/private collaboration to help protect private
infrastructure sectors.
In my testimony today, I will discuss the management and operational
structures used by the ISACs, including their estimated sector
participation, business and funding models, and information sharing and
analysis mechanisms. I will then discuss activities by DHS and other
federal agencies with responsibilities for specific infrastructure
sectors to interact and support the ISACs. Lastly, I will discuss some
of the ISAC-identified challenges to and successful practices for their
establishment, operation, and partnership with the federal government.
As agreed, this testimony includes initial results of our ongoing
analysis of private-sector ISACs, which was requested by your
subcommittees. In conducting this work, we contacted officials from the
15 different ISAC organizations that had been established at the time
of our review: Chemical, Electricity, Energy, Emergency Management and
Response, Financial Services, Food, Information Technology, Multi-
State, Public Transit, Real Estate, Research and Education Networking,
Surface Transportation, Telecommunications, Highway, and Water.
Through structured interviews with these officials, we obtained and
analyzed information to describe the ISACs' current organization and
operational models, funding mechanisms, sector representation and
membership criteria, as well as their challenges and successful
practices in establishing effective information-sharing relationships
within their sectors and with the federal government. We also contacted
officials of the Healthcare Sector Coordinating Council to discuss
their efforts to establish an ISAC for the healthcare sector. Further,
we contacted officials of the ISAC Council, which was created by 11
ISACs to address common issues, and we obtained and analyzed its series
of white papers on a range of ISAC-related issues and challenges.
Within the federal government, we obtained and analyzed information on
efforts to work with the private sector by DHS and other agencies
assigned responsibilities for specific industry sectors, including the
Departments of Agriculture, Energy, Health and Human Services, and the
Treasury and the Environmental Protection Agency. We did not validate
the accuracy of the data provided by the ISACs, DHS, or other agencies.
We performed our work from November 2003 to April 2004, in accordance
with generally accepted government auditing standards.
Results in Brief:
Beginning with PDD 63, federal policy has encouraged the voluntary
creation of ISACs as key information-sharing mechanisms between the
federal government and critical infrastructures. While PDD 63 suggested
certain ISAC activities, CIP policy has essentially left the actual
design and function of the ISACs to the entities that formed them. As a
result, although their overall missions are similar, the current ISACs
were established and developed based on the unique characteristics and
needs of their individual sectors. They operate under different
management and operational structures and, among other things, have
different business models and funding mechanisms. For example, most are
managed or operated as private entities, and some, such as the Water
and Chemical ISACs, are part of associations that represent their
sectors. Others have partnered with government agencies, such as the
Telecommunications ISAC, which is a government/industry operational and
collaborative body sponsored by DHS's National Communications Systems/
National Coordinating Center (NCC). Different funding mechanisms used
by the ISACs include fee-for-service, association sponsorship, federal
grants, and/or voluntary or in-kind operations by ISAC participants.
ISACs that use fee-for-service funding include the Financial Services,
Information Technology, and Water ISACs, that offer tiered memberships
with fees based on the level of service provided.
DHS and the sector-specific agencies have undertaken a number of
efforts to address the public/private partnership called for by federal
CIP policy and continue to work on their cooperation and interaction
with the ISACs and with each other. For example, in January 2004, DHS
held a 2-day conference to describe the information it is analyzing and
its use in the partnership with the private sector and to discuss
information sharing between the federal government and the private
sector. Also, in February, the department established the Protected
Critical Infrastructure Information (PCII) Program, which enables the
private sector to voluntarily submit infrastructure information to the
government that can be protected from disclosure according to
provisions of the Critical Infrastructure Information Act of 2002.
According to ISAC representatives and a council that represents many of
the ISACs, a number of challenges to their successful establishment,
operation, and partnership with DHS and other federal agencies remain.
These challenges include increasing the percentage of sector entities
that are members of the ISACs; building trusted relationships and
processes to facilitate information sharing; overcoming barriers to
information sharing--including the sensitivity of the information,
legal limits on disclosure (such as Privacy Act limitations on
disclosure of personally identifiable information), and contractual and
business limits on how and when information is disclosed--and
clarifying the roles and responsibilities of the various government and
private-sector entities involved in protecting the critical
infrastructures; and funding ISAC operations and activities. According
to a DHS official, these issues are being considered and should be
clarified through the department's development of a plan that documents
the current information-sharing relationships between DHS, the ISACs,
and other agencies; goals for improving that information-sharing
relationship; and methods for measuring progress.
Background:
As reliance on our nation's critical infrastructures grows, so do the
potential threats and attacks that could disrupt critical systems and
operations. In response to the potential consequences, federal
awareness of the importance of securing our nation's critical
infrastructures, which underpin our society, economy, and national
security, has been evolving since the mid-1990s. For example,
Presidential Decision Directive 63 (PDD 63), issued in 1998, described
the federal government's strategy for cooperative efforts with state
and local governments and the private sector to protect the systems
that are essential to the minimum operations of the economy and the
government from physical and cyber attack. In 2002, the Homeland
Security Act created the Department of Homeland Security, which was
given responsibility for developing a national plan; recommending
measures to protect the critical infrastructure; and collecting,
analyzing, and disseminating information to government and private-
sector entities to deter, prevent and respond to terrorist attacks.
More recently, HSPD-7, issued in December 2003, defined federal
responsibilities for critical infrastructure protection, superseding
PDD 63.
CIP Policy Has Continued to Evolve:
Federal awareness of the importance of securing our nation's critical
infrastructures has continued to evolve since the mid-1990s. Over the
years, a variety of working groups has been formed, special reports
written, federal policies issued, and organizations created to address
the issues that have been raised. Key documents that have shaped the
development of the federal government's CIP policy include:
* Presidential Decision Directive 63 (PDD 63),
* The Homeland Security Act of 2002,
* The National Strategies for Homeland Security, to Secure Cyberspace
and for the Physical Protection of Critical Infrastructures and Key
Assets, and:
* Homeland Security Presidential Directives 7 (HSPD-7) and 9 (HSPD-9).
Presidential Decision Directive 63 Established an Initial CIP Strategy:
In 1998, the President issued PDD 63, which described a strategy for
cooperative efforts by government and the private sector to protect the
physical and cyber-based systems essential to the minimum operations of
the economy and the government. PDD 63 called for a range of actions
that were intended to improve federal agency security programs, improve
the nation's ability to detect and respond to serious computer-based
and physical attacks, and establish a partnership between the
government and the private sector. Although it was superseded in
December 2003 by HSPD-7, PDD 63 provided the foundation for the
development of the current sector-based CIP approach.
To accomplish its goals, PDD 63 established and designated
organizations to provide central coordination and support, including
the National Infrastructure Protection Center (NIPC), an organization
within the FBI, which was expanded to address national-level threat
assessment, warning, vulnerability, and law enforcement investigation
and response.
To ensure the coverage of critical sectors, PDD 63 identified eight
infrastructures and five functions. For each of the infrastructures and
functions, the directive designated lead federal agencies, referred to
as sector liaisons, to work with their counterparts in the private
sector, referred to as sector coordinators. Among other
responsibilities, PDD 63 stated that sector liaisons should identify
and access economic incentives to encourage sector information sharing
and other desired behavior.
To facilitate private-sector participation, PDD 63 also encouraged the
voluntary creation of information sharing and analysis centers (ISACs)
to serve as mechanisms for gathering, analyzing, and appropriately
sanitizing and disseminating information to and from infrastructure
sectors and the federal government through NIPC. PDD 63 also suggested
several key ISAC activities to effectively gather, analyze, and
disseminate information--activities that could improve the security
postures of the individual sectors and provide an improved level of
communication within and across sectors and all levels of government.
These activities are: establishing baseline statistics and patterns on
the various infrastructures; serving as a clearinghouse for information
within and among the various sectors; providing a library of historical
data for use by the private sector and government, and reporting
private-sector incidents to NIPC.
The Homeland Security Act of 2002 Established the Department's CIP
Responsibilities:
The Homeland Security Act of 2002, signed by the President on November
25, 2002, established DHS. To help accomplish its mission, the act
established five undersecretaries, among other entities, with
responsibility over directorates for management, science and
technology, information analysis and infrastructure protection, border
and transportation security, and emergency preparedness and response.
The act made the Information Analysis and Infrastructure Protection
(IAIP) Directorate within the department responsible for CIP functions
and transferred to it the functions, personnel, assets, and liabilities
of several existing organizations with CIP responsibilities, including
NIPC (other than the Computer Investigations and Operations Section).
IAIP is responsible for accessing, receiving, and analyzing law
enforcement information, intelligence information, and other threat and
incident information from respective agencies of federal, state, and
local governments and the private sector, and for combining and
analyzing such information to identify and assess the nature and scope
of terrorist threats. IAIP is also tasked with coordinating with other
federal agencies to administer the Homeland Security Advisory System to
provide specific warning information along with advice on appropriate
protective measures and countermeasures. Further, IAIP is responsible
for disseminating, as appropriate, information analyzed by DHS, within
the department, to other federal agencies, state and local government
agencies, and private-sector entities.
Moreover, as stated in the Homeland Security Act of 2002, IAIP is
responsible for (1) developing a comprehensive national plan for
securing the key resources and critical infrastructure of the United
States and (2) recommending measures to protect the key resources and
critical infrastructure of the United States in coordination with other
federal agencies and in cooperation with state and local government
agencies and authorities, the private sector, and other entities.
National Strategies Establish Information-Sharing Initiatives:
The National Strategy for Homeland Security identifies information
sharing and systems as one foundation for evaluating homeland security
investments across the federal government. It also identifies
initiatives to enable critical infrastructure information sharing and
to integrate sharing across state and local government, private
industry, and citizens. Consistent with the original intent of PDD 63,
the National Strategy for Homeland Security states that, in many cases,
sufficient incentives exist in the private market for addressing the
problems of CIP. However, the strategy also discusses the need to use
all available policy tools to protect the health, safety, or well-being
of the American people. It mentions federal grant programs to assist
state and local efforts, legislation to create incentives for the
private sector, and, in some cases, regulation.
The National Strategy to Secure Cyberspace provides an initial
framework for both organizing and prioritizing efforts to protect our
nation's cyberspace. It also provides direction to federal departments
and agencies that have roles in cyberspace security and identifies
steps that state and local governments, private companies and
organizations, and individual Americans can take to improve our
collective cybersecurity. The strategy warns that the nation's private-
sector networks are increasingly targeted and will likely be the first
organizations to detect attacks with potential national significance.
According to the cyberspace strategy, ISACs, which possess unique
operational insight into their industries' core functions and will help
provide the necessary analysis to support national efforts, are
expected to play an increasingly important role in the National
Cyberspace Security Response System[Footnote 2] and the overall
missions of homeland security. In addition, the cyberspace strategy
identifies DHS as the central coordinator for cyberspace efforts and
requires it to work closely with the ISACs to ensure that they receive
timely and threat and vulnerability data that can be acted on and to
coordinate voluntary contingency planning efforts. The strategy
reemphasizes that the federal government encourages the private sector
to continue to establish ISACs and, further, to enhance the analytical
capabilities of existing ISACs. Moreover, the strategy stresses the
need to improve and enhance public/private information sharing about
cyber attacks, threats, and vulnerabilities and to encourage broader
information sharing on cybersecurity among nongovernmental
organizations with significant computing resources. The National
Strategy to Secure Cyberspace also states that the market is to provide
the major impetus to improve cybersecurity and that regulation will not
become a primary means of securing cyberspace.
The National Strategy for the Physical Protection of Critical
Infrastructures and Key Assets provides a statement of national policy
to remain committed to protecting critical infrastructures and key
assets from physical attacks. It outlines three key objectives to focus
the national protection effort: (1) identifying and assuring the
protection of the most critical assets, systems, and functions;
(2) assuring the protection of infrastructures that face an imminent
threat; and (3) pursuing collaborative measures and initiatives to
assure the protection of other potential targets. The National Strategy
for the Physical Protection of Critical Infrastructures and Key Assets
also states that further government leadership and intense
collaboration between public-and private-sector stakeholders is needed
to create a more effective and efficient information-sharing process to
enable our core protective missions. Some of the specific initiatives
include:
* defining protection-related information requirements and
establishing effective, efficient information-sharing processes;
* promoting the development and operation of critical sector ISACs,
including developing advanced analytical capabilities;
* improving processes for domestic threat data collection, analysis,
and dissemination to state and local governments and private industry;
and:
* completing implementation of the Homeland Security Advisory System.
The National Strategy for the Protection of Critical Infrastructures
and Key Assets reiterates that additional regulatory directives and
mandates should be necessary only in instances where the market forces
are insufficient to prompt the necessary investments to protect
critical infrastructures and key assets.
Current Federal Agency CIP Responsibilities:
In December 2003, the President issued HSPD-7, which established a
national policy for federal departments and agencies to identify and
prioritize critical infrastructure and key resources and to protect
them from terrorist attack. It superseded PDD 63. HSPD-7 defines
responsibilities for DHS, sector-specific agencies (formerly referred
to as lead agencies) that are responsible for addressing specific
critical infrastructure sectors, and other departments and agencies. It
instructs federal departments and agencies to identify, prioritize, and
coordinate the protection of critical infrastructure to prevent, deter,
and mitigate the effects of attacks.
The Secretary of Homeland Security is assigned several
responsibilities, including:
* coordinating the national effort to enhance critical infrastructure
protection;
* identifying, prioritizing, and coordinating the protection of
critical infrastructure, emphasizing protection against catastrophic
health effects or mass casualties;
* establishing uniform policies, approaches, guidelines, and
methodologies for integrating federal infrastructure protection and
risk management activities within and across sectors; and:
* serving as the focal point for cyberspace security activities,
including analysis, warning, information sharing, vulnerability
reduction, mitigation, and recovery efforts for critical infrastructure
information systems.
To ensure the coverage of critical sectors, HSPD-7 designated sector-
specific agencies for the critical infrastructure sectors identified in
the National Strategy for Homeland Security (see table 1). These
agencies are responsible for infrastructure protection activities in
their assigned sectors, which include:
* coordinating and collaborating with relevant federal agencies, state
and local governments, and the private sector to carry out their
responsibilities;
* conducting or facilitating vulnerability assessments of the sector;
* encouraging the use of risk management strategies to protect against
and mitigate the effects of attacks against the critical
infrastructure;
* identifying, prioritizing, and coordinating the protection of
critical infrastructure;
* facilitating the sharing of information about physical and cyber
threats, vulnerabilities, incidents, potential protective measures,
and best practices; and:
* reporting to DHS on an annual basis on their activities to meet these
responsibilities.
Further, the sector-specific agencies are to continue to encourage the
development of information-sharing and analysis mechanisms and to
support sector-coordinating mechanisms. HSPD-7 does not suggest any
specific ISAC activities.
Table 1: Critical Infrastructure Sectors Identified by the National
Strategy for Homeland Security and HSPD-7:
Sector: Agriculture; Description: Provides for the fundamental need for
food. The infrastructure includes supply chains for feed and crop
production; Sector-specific agency: Department of Agriculture.
Sector: Banking and Finance; Description: Provides the financial
infrastructure of the nation. This sector consists of commercial banks,
insurance companies, mutual funds, government-sponsored enterprises,
pension funds, and other financial institutions that carry out
transactions including clearing and settlement; Sector-specific
agency: Department of the Treasury.
Sector: Chemicals and hazardous materials; Description: Transforms
natural raw materials into commonly used products benefiting society's
health, safety, and productivity. The chemical industry represents a
$450 billion enterprise and produces more than 70,000 products that are
essential to automobiles, pharmaceuticals, food supply, electronics,
water treatment, health, construction, and other necessities; Sector-
specific agency: Department of Homeland Security.
Sector: Defense industrial base; Description: Supplies the military
with the means to protect the nation by producing weapons, aircraft,
and ships and providing essential services, including information
technology and supply and maintenance; Sector-specific agency:
Department of Defense.
Sector: Emergency services; Description: Saves lives and property from
accidents and disaster. This sector includes fire, rescue, emergency
medical services, and law enforcement organizations; Sector-specific
agency: Department of Homeland Security.
Sector: Energy; Description: Provides the electric power used by all
sectors, including critical infrastructures, and the refining, storage,
and distribution of oil and gas. The sector is divided into electricity
and oil and natural gas; Sector-specific agency: Department of Energy.
Sector: Food; Description: Carries out the post-harvesting of the food
supply, including processing and retail sales; Sector-specific agency:
Department of Agriculture and Department of Health and Human Services.
Sector: Government; Description: Ensures national security and freedom
and administers key public functions; Sector-specific agency:
Department of Homeland Security.
Sector: Information technology and telecommunications; Description:
Provides communications and processes to meet the needs of businesses
and government; Sector-specific agency: Department of Homeland
Security.
Sector: Postal and shipping; Description: Delivers private and
commercial letters, packages, and bulk assets. The U.S. Postal Service
and other carriers provide the services of this sector; Sector-
specific agency: Department of Homeland Security.
Sector: Public Health and Healthcare; Description: Mitigates the risk
of disasters and attacks and also provides recovery assistance if an
attack occurs. The sector consists of health departments, clinics, and
hospitals; Sector-specific agency: Department of Health and Human
Services.
Sector: Transportation; Description: Enables movement of people and
assets that are vital to our economy, mobility, and security with the
use of aviation, ships, rail, pipelines, highways, trucks, buses, and
mass transit; Sector-specific agency: Department of Homeland Security.
Sector: Drinking water and water treatment systems; Description:
Sanitizes the water supply with the use of about 170,000 public water
systems. These systems depend on reservoirs, dams, wells, treatment
facilities, pumping stations, and transmission lines; Sector-specific
agency: Environmental Protection Agency.
Source: GAO analysis based on the President's National Strategy
documents and HSPD-7.
[End of table]
In January, the President issued HSPD-9, which established a national
policy to defend the agriculture and food system against terrorist
attacks, major disasters, and other emergencies. HSPD-9 defines
responsibilities for DHS, lead federal agencies, or sector-specific
agencies, responsible for addressing specific critical infrastructure
sectors, and other departments and agencies. It instructs federal
departments and agencies to protect the agriculture and food system
from terrorist attacks, major disasters, and other emergencies by:
* identifying and prioritizing sector-critical infrastructure and key
resources for establishing protection requirements,
* developing awareness and early warning capabilities to recognize
threats,
* mitigating vulnerabilities at critical production and processing
nodes,
* enhancing screening procedures for domestic and imported products,
and:
* enhancing response and recovery procedures.
In addition, the Secretary of Homeland Security, in coordination with
the Secretaries of Agriculture, Health and Human Services, and other
appropriate federal department and agencies, are assigned
responsibilities including:
* expanding and continuing vulnerability assessments of the agriculture
and food sectors and:
* working with appropriate private-sector entities to establish an
effective information-sharing and analysis mechanism for agriculture
and food.
Prior GAO Recommendations:
We have made numerous recommendations over the last several years
related to information-sharing functions that have been transferred to
DHS. One significant area of our work concerns the federal government's
CIP efforts, which is focused on sharing information on incidents,
threats, and vulnerabilities and providing warnings related to critical
infrastructures both within the federal government and between the
federal government and state and local governments and the private
sector. Although improvements have been made in protecting our nation's
critical infrastructures and continuing efforts are in progress,
further efforts are needed to address the following critical CIP
challenges that we have identified:
* developing a comprehensive and coordinated national plan to
facilitate CIP information sharing that clearly delineates the roles
and responsibilities of federal and nonfederal CIP entities, defines
interim objectives and milestones, sets timeframes for achieving
objectives, and establishes performance measures;
* developing fully productive information-sharing relationships within
the federal government and among the federal government and state and
local governments and the private sector;
* improving the federal government's capabilities to analyze incident,
threat, and vulnerability information obtained from numerous sources
and share appropriate timely, useful warnings and other information
concerning both cyber and physical threats to federal entities, state
and local governments, and the private sector; and:
* providing appropriate incentives for nonfederal entities to increase
information sharing with the federal government.
ISAC Structures and Operations Reflect Sector Needs and Evolving Goals:
PDD 63 encouraged the voluntary creation of ISACs and suggested some
possible activities, as discussed earlier; however, their actual design
and functions were left to the private sector, along with their
relationships with the federal government. HSPD-7 continues to
encourage the development of information-sharing mechanisms and does
not suggest specific ISAC activities. As a result, the ISACs have been
designed to perform their missions based on the unique characteristics
and needs of their individual sectors and, although their overall
missions are similar, they have different characteristics. They were
created to provide an information sharing and analysis capability for
members of their respective infrastructure sectors in order to support
efforts to mitigate risk and provide effective response to adverse
events, including cyber, physical, and natural events. In addition, the
ISACs have taken several steps to improve their capabilities and the
services they provide to their respective sectors.
Management and Operational Structures Vary, but Provide Similar Basic
Capabilities:
The ISACs have developed diverse management structures and operations
to meet the requirements of their respective critical infrastructure
sectors. To fulfill their missions, they have been established using
various business models, diverse funding mechanisms, and multiple
communication methods.
Business model--ISACs use different business models to accomplish their
missions. Most are managed or operated as private entities, including
the Financial Services, Chemical, Electricity Sector, Food, Information
Technology, Public Transit, Real Estate, Surface Transportation,
Highway, and Water ISACs. Many are established as part of an
association that represents a segment of or an entire critical
infrastructure sector. For example, the Association of Metropolitan
Water Authorities manages the contract for the Water ISAC and the
American Chemistry Council manages and operates the Chemical ISAC
through its CHEMTRAC.[Footnote 3] In addition, the North American
Electric Reliability Council (NERC), [Footnote 4] a nonprofit
corporation that promotes electric system reliability and security,
operates the Electricity Sector ISAC using internal expertise.
The legal structure of the ISACs continues to evolve. The Financial
Services ISAC has evolved from a limited liability corporation in 1999
to a 501(c)6 non-stock corporation and is managed by a board of
directors that is comprised of representatives from the Financial
Services ISAC's members. According to the Financial Services ISAC
Board, the change to be a 501(c)6 non-stock corporation, as mentioned
above, was made to simplify the membership agreement and to make the
process for obtaining public funding easier. The Energy ISAC also
changed from a limited liability corporation to a 501(c)3 nonprofit
charitable organization to eliminate membership barriers.
Also, government agencies have partnered with the private sector to
operate certain ISACs. For example, DHS's National Communications
Systems/ National Coordinating Center (NCC) for Telecommunications
sponsors the Telecommunications ISAC, which is a government/industry
operational and collaborative body.[Footnote 5] DHS provides for the
Telecommunications ISAC facilities, tools and systems, the NCC manager,
and the 24x7 watch operations staff. The private sector provides
representatives who have access to key corporate personnel and other
resources. In addition, DHS's United States Fire Administration
operates the Emergency Management and Response ISAC. New York State,
through its Office of Cyber Security and Critical Infrastructure
Coordination, is coordinating efforts of the Multi-state ISAC. The New
York State Office of Cyber Security and Critical Infrastructure
Coordination is currently studying best practices and lessons learned
to assist in developing a structure that will include representation by
member states.
Six of the ISACs included in our study use contractors to perform their
day-to-day operations. According to an Association of Metropolitan
Water Agencies (AMWA) official, they chose a contractor to operate the
Water ISAC because the contractor had the appropriate expertise. In
addition, the contractor's personnel had government clearances and the
ability to operate a secure communication system and facility. In
addition, ISACs use contractors to supplement their operations. For
example, a formal contract provides for the daily staffing and
performance of the Emergency Management and Response ISAC's tasks. It
chose this model because of federal requirements and the shortage of
positions for federal full-time employees at the United States Fire
Administration. The Telecommunications ISAC contracted for analysts to
operate its 24 x 7 watch operations under the management of a
government official.
ISACs also differ in the nature of the hazards that they consider:
cyber, physical, or all hazards (including natural events such as
hurricanes). For example, during events of the power outage in August
2003 and Hurricane Isabel in September 2003, the Financial Services
ISAC was contacted by DHS to determine the Banking and Finance sector's
preparedness and the impact of those events. However, the Multi-state
ISAC will remain focused on cyber threats because other state
organizations are in place to address physical and natural disaster
events.
Funding--ISACs fund their activities using a variety of methods--fees-
for-service, association sponsorship, federal grants, and voluntary, or
in-kind operations by existing participants. For example, the Financial
Services, Information Technology, and Water ISACs use a tiered fee-for-
service model for members. This model establishes different tiers of
membership based on the level of service provided. These tiers
typically include some basic level of service that is provided at
minimal or no cost to the member and additional tiers that provide--for
a fee--more personalized service and access to additional resources. To
help ensure that cost is not a deterrent to membership and that the
ISAC's coverage of its sector is extensive, the Financial Services ISAC
recently, as part of its next-generation ISAC effort, shifted to a
tiered fee-for-service approach. It offers five levels of service that
vary in cost--Basic (no charge), Core ($750 per year), Premier ($10,000
per year), Gold ($25,000 per year), and Platinum ($50,000)--for
ascending levels of information and analytical capabilities. In
addition, there is a partner-level license agreement for select
industry associations ($10,000) for distribution to eligible
association members of Urgent and Crisis Alerts. For example, the
Information Technology ISAC recently started to work on a tiered basis
with fees set annually at $40,000; $25,000; $5,000; $1,000; and free.
The Water ISAC also uses a tiered approach, with membership fees
ranging from $7,500 to $750 annually. The Surface Transportation ISAC
assesses an annual fee from its Class I railroad members of
approximately $7,500.
Some industry associations that operate ISACs fund them from budgets.
For example, the North American Electric Reliability Council (NERC)
funds the Electricity Sector ISAC, and the American Trucking
Association funds the Highway ISAC from their budgets. The American
Chemistry Council fully funds the Chemical ISAC through the previously
existing Chemical Transportation Emergency Center, known as CHEMTRAC.
The ten trade associations that are members of it fund the Real Estate
ISAC.
In addition, some ISACs receive funding from the federal government for
such purposes as helping to start operations, funding memberships, and
providing expanded capabilities. Examples include the following:
* The Public Transit ISAC initially received a $1.2 million grant from
the Federal Transit Administration (FTA) to begin operations. Members
pay no an annual fee and there are no membership requirements from the
association that started the ISAC--the American Public Transportation
Association.
* For FY 2004, the Water ISAC received a $2 million grant from EPA to
cover annual operating costs, including the expansion of memberships to
smaller utilities.
* The Financial Services ISAC received $2 million dollars from the
Department of the Treasury to enhance its capabilities, including
technology to broaden membership service.
* The Highway ISAC received initial funding from DHS's Transportation
Security Administration (TSA) to start the ISAC.
* The Energy ISAC received federal grants to assist entities within its
separate sectors to be members.
* DHS provides funding for the operation of the Telecommunications ISAC
that is combined with in-kind services provided by the corporate
participants. DHS also fully operates the Emergency Management and
Response ISAC.
States also provide funding for ISACs. For example, the Multi-state
ISAC is funded by and functions as part of the New York State Cyber
Security Analysis Center. In addition, the Research and Education
Networking ISAC is supported by Indiana University.
Sharing mechanisms--ISACs use various methods to share information with
their members, other ISACs, and the federal government. For example,
they generally provide their members access to electronic information
via e-mail and Web sites. For example, the Chemical ISAC members
receive e-mail alerts and warnings in addition to the information that
is posted to the ISAC's Web site. The Highway ISAC provides members on
its Web site with links to IT resources.
Some ISACs also provide secure members-only access to information on
their Web sites. For example, the Financial Services ISAC's Web site
offers multiple capabilities for members at the premier level and
above, including, among other things, access to news, white papers,
best practices, and contacts. The Energy ISAC offers its members access
to a secure Web site.
In addition, some ISACs hold conference calls for their members. For
example, the Chemical ISAC holds biweekly conference calls with DHS.
The Financial Services ISAC also conducts threat intelligence
conference calls every two weeks for premier members and above with
input from Science Applications International Corporation (SAIC) and
DHS. These calls discuss physical and cyber threats, vulnerabilities
and incidents that have occurred during the previous two weeks, and
they provide suggestions on what may be coming. The Financial Services
ISAC is capable of organizing crisis conference calls within an hour of
the notification of a Crisis Alert, and it hosts regular biweekly
threat conference calls for remediation of vulnerabilities (viruses,
patches).
ISACs also use other methods to communicate. For example, they may use
pagers, phone calls, and faxes to disseminate information. In addition,
the Telecommunications ISAC uses the Critical Infrastructure Warning
Information Network (CWIN).[Footnote 6] The Financial Services ISAC
also sponsors twice yearly members' only conferences to learn and share
information.
ISAC Coverage and Participation Varies:
According to the ISAC Council, its membership possesses an outreach and
connectivity capability to approximately 65 percent of the U.S. private
critical infrastructure. However, the ISACs use various matrices to
define their respective sectors' participation in their activities. For
example, the Banking and Finance sector has estimated that there are
more than 25,000 financial services firms in the United States. Of
those, according to the Financial Services ISAC Board, roughly 33
percent receive Urgent and Crisis Alerts through license agreements
with sector associations; these firms account for the vast majority of
total commercial bank assets, the majority of assets under management,
and the majority of securities/ investment bank transactions that are
handled by the sector, but less than half the sector's insurance
assets. According to an American Public Transportation Association
official, the Public Transit ISAC covers a little less than 5 percent
of the public transit agencies; however, those agencies handle about 60
to 70 percent of the total public transit ridership. Further, according
to NERC officials, virtually all members of NERC are members of the
Electricity Sector ISAC. As for the Energy ISAC, officials stated that
its 80-plus members represent approximately 85 percent of the energy
industry. Membership in the Information Technology ISAC also represents
85 to 90 percent of the industry, including assets of Internet
equipment hardware, software, and security providers. For other ISACs,
such as Chemical and Real Estate, officials stated that it is difficult
to determine the percentage of the sector that is included.
Table 2 provides a summary of the characteristics of the ISACs that we
included in our review. In addition to these ISACs, the Healthcare
sector is continuing to organize, including efforts to establish an
ISAC. According to:
DHS officials, the Emergency Law Enforcement ISAC that was formally
operated by the NIPC and transferred to IAIP is not currently staffed
and will be considered in current efforts to organize the Emergency
Services sector.
Table 2: Summary of ISAC Characteristics:
Critical Infrastructures and their ISAC(s): Agriculture; None at this
time;
Critical Infrastructures and their ISAC(s): Banking & Finance;
Financial Services (est. Oct. 1999);
Coverage: 200 members, including commercial banks, securities firms,
and insurance companies; Represents 90% of the financial sector's
assets;
Funding model: Funded by and operated with tiered membership fees;
Contractor operated;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24 hours a day, 7 days a week; Watch desk
analyzes and categorizes threats, incidents, and warnings based on the
sector's needs;
Sharing mechanisms: Text-based alerts, through a notification system,
backed up by telephone; Biweekly threat intelligence conference call
with DHS and SAIC.
Critical Infrastructures and their ISAC(s): Chemicals & Hazardous
Materials; Chemical (est. April 2002);
Coverage: 538 individual members representing the chemical industries;
285 businesses; Represents 90% of chemical sector;
Funding model: Funded and operated by ACC's Chemical Transportation
Emergency Center;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24x7; Currently working to develop an
analysis center;
Sharing mechanisms: E-mails alerts and warnings; Chemistry ISAC Web
site; Biweekly conference calls with DHS; Secure communications network
with DHS.
Critical Infrastructures and their ISAC(s): Defense Industrial Base;
None at this time.
Critical Infrastructures and their ISAC(s): Emergency Services;
Emergency Management & Response (est. Oct. 2000);
Coverage: 10 FEMA Regions; 6 major stakeholders of EMR sector;
Represents 100% of the essential components of the EMR Sector;
Funding model: Funded by FEMA's Office of Cyber Security with
supplementation from USFA; Contractor operated;
Hazards covered: Cyber; Physical;
Analysis capability: Developing 24x7 operations; Analyzes and
disseminates actionable intelligence on threats, attacks,
vulnerabilities, anomalies, and security best practices;
Sharing mechanisms: Electronic messaging; Telephone and when necessary,
a secure telephone unit.
Critical Infrastructures and their ISAC(s): Energy; Electric (est. Oct.
2000);
Coverage: More then 90% of NERC members are members of the ISAC
including large and small electric utilities, regional electric utility
companies, and power marketers;
Funding model: Funded and managed/ operated by NERC;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24x7; The ES-ISAC and NERC have created
the Indications, Analysis, and Warnings Program (IAW) that provides a
set of guidelines for reporting operational and cyber incidents that
adversely affect the electric power infrastructure;
Sharing mechanisms: Secure telephone, fax, and Web server; E-mail;
Satellite telephones; Information such as incident reports and
warnings, vulnerability assessments, and related documents are posted
on the public Web site.
Critical Infrastructures and their ISAC(s): Energy; Energy (est. Nov.
2001);
Coverage: 80 plus members from the oil and gas sector; Represents 85%
of the oil and gas sector;
Funding model: Funded by grants from DOE; Contractor operated;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24x7; Analyzes threats, vulnerabilities,
and incident information; Provides security information and solutions;
Sharing mechanisms: Conference calls; Fax, Email, pager; Detailed
information on warnings provided on a membership only, secure Web site.
Critical Infrastructures and their ISAC(s): Food (est. Feb. 2002);
Coverage: Over 40 food-industry trade associations and their members;
Funding model: No current funding. Operated by volunteer labor from
each member association;
Hazards covered: Physical;
Analysis capability: Operates 24x7; No analysis capability, due to
members' privacy concerns. Depends on DHS for analysis;
Sharing mechanisms: E- mail; Watch Commander List; Currently working to
develop a secure e- mail system.
Critical Infrastructures and their ISAC(s): Government; State Gov.
(est. Jan. 2003);
Coverage: 49 states (excluding Kansas) and the District of Columbia;
Funding model: Funded and operated by New York State; States provide
time and resources as appropriate;
Hazards covered: Cyber; Physical & Natural (as it relates to cyber);
Analysis capability: Operates 24x7; Issues bulletins, advisories, and
alerts;
Sharing mechanisms: Monthly conference calls; E-mail; Telephone.
Critical Infrastructures and their ISAC(s): Information Technology &
Telecommunications; (est. Dec. 2000);
Coverage: 90% of all desktop operating systems; 85% of all databases;
50% of all desktop computers; 85% of all routers; 65% of software
security;
Funding model: Funded and operated by foundational member
contributions, will soon implement membership fees (tiered); Contractor
operated;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24x7; Analyzes cyber alerts and
advisories and reports physical issues;
Sharing mechanisms: CWIN; Encrypted e-mail; SSL-protected Web sites;
Cellular phones; VoIP telephony; GETS system for priority calls.
Critical Infrastructures and their ISAC(s): Information Technology &
Telecommunications; Telecom (est. Jan. 2000);
Coverage: 95% of wireline providers; Over 60% of wireline vendors; 95%
of wireless providers; 90% of wireless vendors; 42% of Internet Service
subscribers; 90% of Internet Service networks; 6 of the top system
integrators in the U.S. Federal IT market; 15% of Domain Name Service
root and global Top Level Domain operators;
Funding model: Funded by NCS; Operated by NCC; Agencies bear the costs
of their own personnel;
Hazards covered: Cyber; Physical; Natural;
Analysis capability: Operates 24x7; Analyzes data to avoid crises that
could affect the entire telecom infrastructure;
Sharing mechanisms: E-mail; Telephone; Fax; Meetings; CWIN.
Critical Infrastructures and their ISAC(s): Information Technology &
Telecommunications; Research & Education Networking (est. Feb. 2003);
Coverage: 200 Universities; All U.S. universities and colleges that are
connected to national R&E networks have basic membership;
Funding model: Funded and operated by Indiana University;
Hazards covered: Cyber;
Analysis capability: Operates 24x7; Receives and disseminates
information regarding network security vulnerabilities and threats in
the higher education community;
Sharing mechanisms: Public information restricted to aggregate views of
the network; Information identifying institutions or individuals not
reported publicly; Detailed and sensitive information shared only with
affected institutions.
Critical Infrastructures and their ISAC(s): Postal & Shipping; None at
this time.
Critical Infrastructures and their ISAC(s): Public Health & Healthcare;
HealthCare; None at this time.
Critical Infrastructures and their ISAC(s): Transportation; Public
Transit (est. Jan. 2003);
Coverage: Approximately 100 of the major national transit
organizations;
Funding model: Federally funded; Contractor operated;
Hazards covered: Cyber; Physical;
Analysis capability: Operations 24x7; Collects, analyzes, and
disseminates security information;
Sharing mechanisms: E-mail tree; Secure e-mail; Public Transit Web
site; Links to HSOC, and DOT and TSA's Operation Centers.
Critical Infrastructures and their ISAC(s): Transportation; Surface
Transportation (est. May 2002);
Coverage: Includes the major North American freight railroads and
Amtrak; Represents 95% of the U.S. freight railroad industry and
Amtrak;
Funding model: Funded by membership fees and a grant from the Federal
Transit Administration (FTA); Contractor operated;
Hazards covered: Cyber; Physical Natural;
Analysis capability: Operates 24x7; Conducts mid-to long-term technical
analysis on all threats;
Sharing mechanisms: Surface Transportation Web site; Secure telephone.
Critical Infrastructures and their ISAC(s): Transportation; Highway
(est. March 2003);
Coverage: Over 90% of the largest for-hire motor carriers; Represents
60% economic activity with over 50% of long haul;
Funding model: Funded and operated by the American Trucking Association
(ATA);
Hazards covered: Cyber; Physical;
Analysis capability: Developing 24x7 operations; Channels warnings,
threat information, and advisories to the industry and to drivers
through its call center;
Sharing mechanisms: Highway ISAC Web site; Highway watch center; Blast
fax; E- mail; Print media communications; Amber alerts.
Critical Infrastructures and their ISAC(s): Drinking Water & Water
Treatment Systems; Water (est. Dec. 2002);
Coverage: 275-300 small and large water utilities; Represents 45% of
water utilities with secure portals; Represents 85% of the water
utilities that receive e-mail alerts;
Funding model: Funded by tired membership fees and a grant from EPA;
Contractor operated; Receives contributions from AMWA;
Hazards covered: Cyber; Physical;
Analysis capability: Operates 24x7; Analyzes threat and incident
information for its potential impact on the sector;
Sharing mechanisms: Encrypted e-mail; Secure portal; Secure electronic
bulletin boards and chat rooms.
Critical Infrastructures and their ISAC(s): Other Sectors That Have
Established ISACs; Real Estate (est. April 2003);
Coverage: 10 trade associations representing hotels, realtors, shopping
centers, and others;
Funding model: Funded by trade associations; Contractor operated;
Hazards covered: Physical;
Analysis capability: Operates 24x7; Depends on DHS for threat
analysis;
Sharing mechanisms: 2-way communications network and Web site;
Conference calls with top executives from various sectors as needed.
[End of table]
Sector Coordinator Roles Differ:
As discussed earlier, federal CIP policy establishes the position of
sector coordinator for identified critical infrastructure sectors to
initiate and build cooperative relationships across an entire
infrastructure sector. In most cases, sector coordinators have played
an important role in the development of their respective infrastructure
sectors' ISACs. In many cases the sector coordinator also manages or
operates the ISAC.
* The North American Electric Reliability Council, as sector
coordinator for the electricity segment of the energy sector, operates
the Electricity Sector ISAC.
* The Association of American Railroads, as a sector coordinator for
the transportation sector, manages the Surface Transportation ISAC.
* The Association of Metropolitan Water Agencies, as the sector
coordinator for the water and wastewater sector, manages the Water
ISAC.
In addition, regarding the telecommunications ISAC, sector coordinators
participate as members of the ISAC. For example, the Cellular
Telecommunications and Internet Association, the United States Telecom
Association, and the Telecommunications Industry Association are all
members of the NCC, which operates the telecommunications ISAC. In the
case of the Financial Services ISAC, no formal relationship exists
between the Banking and Finance Sector Coordinator, the Financial
Services Sector Coordinating Council, and the ISAC; however, according
to Financial Services ISAC officials, there is a good relationship
between them.
Other ISACs were created and are operated without a formal sector
coordinator in place, including the Chemical, Emergency Management and
Response, and Food ISACs.
Council Established to Improve ISACs' Efficiency and Effectiveness:
Eleven ISACs created an ISAC Council to work on various operational,
process, and other common issues to effectively analyze and disseminate
information and, where possible, to leverage the work of the entire
ISAC community. The ISACs initiated this effort without federal
sponsorship. Currently, the participating ISACs include Chemical,
Electricity, Energy, Financial Services, Information Technology,
Public Transit, Surface Transportation, Telecommunications, Highway,
and Water. In addition, the Multi-state and Research and Education
Networking ISACs are participants.
In February 2004, the council issued eight white papers to reflect the
collective analysis of its members and to cover a broad set of issues
and challenges, including:
* Government/Private-Sector Relations. Explains the need for DHS to
clarify its expectations and to develop roles and responsibilities for
the ISACs.
* HSPD-7 Issues and Metrics. Describes specific issues related to the
private sector that DHS should address when responding to HSPD-7.
* Information Sharing and Analysis. Identifies future goals that the
ISACs may want to work on achieving, including developing an
implementation plan.
* Integration of ISACs into Exercises. Discusses the importance of the
ISACs and the private infrastructure sectors being involved in
government exercises that demonstrate responses to possible incidents.
* ISAC Analytical Efforts. Describes the various levels of capabilities
that individual ISACs may want to consider supporting, including cyber
and physical analysis.
* Policy and Framework for the ISAC Community. Identifies common policy
areas that need to be addressed to provide effective, efficient, and
scalable information sharing among ISACs and between ISACs and the
federal government.
* Reach of Major ISACs. Describes and identifies the degree of outreach
that the ISACs have achieved into the U.S. economy. As of September
2003, the ISAC Council estimated that the ISACs had reached
approximately 65 percent of the critical infrastructures they
represent.
* Vetting and Trust. Discusses the processes for sharing information
and the need to develop trust relationships among individual ISAC
members and among the various ISACs.
Federal Efforts to Establish Cooperation and Interaction with the ISACs
Continue:
As outlined in HSPD-7 and presented in table 1, DHS and other federal
agencies are designated as sector-specific agencies for the critical
infrastructure sectors identified. In addition, DHS is responsible for
coordinating the overall national effort to enhance the protection of
the critical infrastructure and key resources of the United States and
has established organizational structures to address its CIP and
information-sharing responsibilities. DHS and the sector-specific
agencies have undertaken a number of efforts to address the public/
private partnership that is called for by federal CIP policy, and they
continue to work on their cooperation and interaction with the ISACs
and with each other.
DHS Actions to Improve Information-Sharing Relationships:
The functions DHS provides to each ISAC differ, and its coordination
and levels of participation vary for each sector-specific agency.
However, the department has undertaken a number of efforts with the
ISACs and sector-specific agencies to implement the public/private
partnership called for by federal CIP policy.
DHS has established functions within the department to support the
ISACs and other CIP efforts. IAIP, as the DHS component directly
responsible for CIP activities, carries out many of these functions.
The Infrastructure Coordination Division within IAIP plays a key role
in coordinating with the ISACs concerning information sharing.
Nonetheless, ISACs may interact with multiple components of the
department. For example, the ISACs may discuss cyber issues with the
National Cyber Security Division. According to a DHS official, the
department does not intend to establish a single point of contact for
ISACs within the department. Rather, the department plans to develop
policies and procedures to ensure effective coordination and sharing of
ISAC contact information among the appropriate DHS components. In
addition, the Infrastructure Coordination Division is in the process of
staffing analysts who are responsible for working with each critical
infrastructure sector. The analysts would serve as the primary point of
contact for the sectors and would address information sharing,
coordination, information protection, and other issues raised by the
sectors.
Further, according to DHS officials, TSA, within the department's
Border and Transportation Security Directorate, is working with
organizations in the private sector to establish information-sharing
relationships. For example, Surface Transportation ISAC analysts stated
that they have a good working relationship with TSA, and TSA's
Operations Center has office space designated for them.
In addition, other DHS actions include the following:
* Last summer, DHS, the Department of Agriculture (USDA), and the
Department of Health and Human Services' (HHS) Food and Drug
Administration (FDA) initiated efforts to organize the agriculture and
food critical infrastructure sectors to raise awareness and improve
security efforts. An introductory conference was held with about 100
leading sector corporations and associations to make the business case
for participating in CIP efforts, including the importance of enhancing
security and sharing information within the sectors.
* In December, DHS hosted a 2-day CIP retreat with ISAC
representatives, sector coordinators, and high-level DHS and White
House Homeland Security Council officials. Participants discussed the
needs, roles, and responsibilities of public-and private-sector
entities related to information sharing and analysis, incident
coordination and response activities, critical infrastructure
information requests, and level of DHS funding. During this retreat,
DHS participated in the first meeting of the Operational Clarity and
Improvement Task Group, which was formed by the ISAC Council and sector
coordinators to address the need for a common conceptual framework and
to clarify current and future efforts to protect the nation's critical
infrastructure.
* In January, DHS's IAIP Directorate held a 2-day conference to
describe the information it is analyzing and the use of that
information in the partnership with the private sector to discuss
information sharing between the federal government and the private
sector.
* In February, the department established the Protected Critical
Infrastructure Information (PCII) Program, which enables the private
sector to voluntarily submit infrastructure information to the
government. DHS's IAIP Directorate is responsible for receiving
submissions, determining if the information qualifies for protection
and, if it is validated, sharing it with authorized entities for use as
specified in the Critical Infrastructure Information Act of 2002.
In addition to the efforts listed above, DHS officials stated that they
provide funding to some of the ISACs. For example, DHS has agreed to
fund tabletop exercises for the Financial Services, Telecommunications,
and Electricity Sector ISACs. DHS anticipates that the tabletop
exercises will be completed by August 2004. Also, DHS expects to fund a
cross-sector tabletop exercise. According to the Financial Services
ISAC, funding for their tabletop exercise is $250,000.
Another effort that DHS has undertaken is to maintain regular contact
with the ISACs. For example, a DHS analyst specializing in the chemical
sector stated that the Chemical ISAC is in daily contact with DHS and
that it participates in DHS-sponsored biweekly threat meetings. The
department also conducts weekly conference calls with several ISACs,
other DHS components, and private-sector organizations to discuss
threats and viruses.
Sector-Specific Agencies Have Taken Action to Assist the ISACs:
HSPD-7 designates federal departments and agencies to be sector-
specific agencies. These federal agencies, among other things, are to
collaborate with the private sector and continue to encourage the
development of information-sharing and analysis mechanisms. In
addition, sector-specific agencies are to facilitate the sharing of
information about physical and cyber threats, vulnerabilities,
incidents, potential protective measures, and best practices. Another
directive, HSPD-9, establishes a national policy to defend the
agriculture and food system against terrorist attacks, major disasters,
and other emergencies. Some sector-specific agencies have taken steps
to help the ISACs to increase their memberships and breadth of impact
within their respective sectors and to improve their analytical and
communications capabilities.
* Environmental Protection Agency (EPA). As noted earlier, EPA is the
sector-specific agency for the water sector. According to EPA
officials, its Office of Water (Water Security Division), which has
been designated as the lead for drinking water and wastewater CIP
efforts, is currently revising EPA's Office of Homeland Security's
Strategic Plan. In addition, the division is working on a General
Strategic Plan, to identify measurable goals and objectives and
determine how the division will accomplish that work. Further, these
officials stated that for fiscal year 2004, EPA issued a $2 million
grant to the Water ISAC to enhance its capabilities, for example, to
fund 24x7 operations and to increase and support ISAC membership. They
also stated that EPA issued $50 million in grants to assist the largest
drinking water utilities in conducting vulnerability assessments. There
are also state grants to build communications networks for
disseminating information, particularly to smaller utility companies.
EPA's Water Security Division also makes publicly available various
resources related to water security including, among other things,
emergency response guidelines, risk assessment and vulnerability
assessment methodologies, and a security product guide. The division
has also developed a "Vulnerability Assessment Factsheet" that gives
utility companies additional guidance on vulnerability assessments.
Moreover, the Water Security Division holds biweekly conference calls
with water associations to promote communications between EPA and the
private sector, and it provides EPA publications and other information
to the Water ISAC through e-mail distribution lists. In addition, the
division has 10 regional offices that work with the states.
* Department of the Treasury (Treasury). As the sector-specific agency
for the Banking and Finance sector, Treasury's Office of CIP and
Compliance Policy is responsible for CIP-related efforts. It has
developed policy for its role as a sector-specific agency. The policy
includes steps to identify vulnerabilities with the assistance of the
institutions, identify actions for remediation, and evaluate progress
in reducing vulnerabilities. A major effort by Treasury was having
consultants work with the Financial Services ISAC's board of directors
to evaluate ways to improve the overall reach and operations of the
ISAC. According to Treasury officials, this effort, in part, led to a
$2 million grant from Treasury to the ISAC for developing the "next
generation" Financial Services ISAC. The one-time grant was earmarked
for enhancing the ISAC's capabilities. Regarding interaction with the
Financial Services ISAC, Treasury informally shares high-level threat
and incident information with the sector through the ISAC. The
department also chairs the Financial and Banking Information
Infrastructure Committee (FBIIC), a group of regulators who coordinate
regulatory efforts to improve the reliability and security of financial
systems. This group has done a number of things to raise awareness and
improve the reliability of the institutions. For example, under the
sponsorship of the Federal Deposit Insurance Corporation, there are
regional outreach briefings that address why the private sector needs
to partner with the federal government to improve its security.
Moreover, FBIIC has sponsored the 3,600 priority telecommunications
circuits for financial institutions under the National Communications
System's Telecommunications Service Priority and Government Emergency
Telecommunications Service programs.
* Department of Energy (DOE). As the sector-specific agency for the
Energy and Electricity sectors, DOE's Office of Energy Assurance is
responsible for fulfilling the roles of critical infrastructure
identification, prioritization, and protection for the energy sector,
which includes the production, refining, and distribution of oil and
gas, and electric power--except for commercial nuclear power
facilities. However, DOE does not address situational threats such as
natural disasters or power outages with its ISACs because, in part, the
ISACs are determining whether it is their role to address these types
of threats. Information sharing with the ISACs is an informal process,
and no written policy exists. For example, DOE is collecting threat
information related to hackers and computer security, but the
department is not disseminating it to the ISACs or to private industry.
The Office of Energy Assurance hopes to clarify and expand on this
subject in its International Program Plan, which is currently in draft
form.
* Department of Health and Human Services (HHS). As mentioned earlier,
HHS is the sector-specific agency for the public health and healthcare
sector, and it shares that role with USDA for the food sector.
Currently, there is no ISAC for the healthcare sector. Efforts to
organize the healthcare sector have been ongoing. In July 2002, HHS
officials and other government and industry participants were invited
to the White House conference center to discuss how they wanted to
organize the sector. A Healthcare Sector Coordinating Council (HSCC)
was formed, and HHS requested that MITRE, its contractor, lend
technical support to the new group as it continues to organize the
sector and establish an ISAC. In addition, HHS officials stated that
the department provided $500,000 for ISAC efforts in fiscal year 2003
and budgeted $1 million for fiscal year 2004. HHS officials stated that
the department would likely be agreeable to continuing to provide
funding for an ISAC. They also stated that an ISAC could be operational
within the next year. In the meantime, HHS is sharing information with
the industry through an e-Community group that MITRE has set up on a
secure Web site.
Agriculture and Food were only recently designated as critical
infrastructure sectors and, as with the healthcare sector, efforts to
organize the sectors are in the beginning stages. HHS has worked with
the Food Marketing Institute-operated Food ISAC since it was
established, but the department has focused more of its efforts on
organizing the agriculture and food sectors. As we mentioned earlier,
HHS helped initiate efforts to organize the sector by holding an
introductory conference last summer for about 100 leading sector
corporations and associations to make the business case for
participating in CIP efforts. Recently, the department cohosted a
meeting with DHS and USDA in which industry participants were asked how
they wished to organize into an infrastructure sector, including
addressing the existence and expansion of the current Food ISAC. As a
result of this meeting, participants agreed to establish a council of
about 10-15 private-sector food and agriculture organizations to
represent the sector. A federal government council will be created to
interact with the private sector and with state and local governments.
The government council will initially include several federal
government agencies and state and local entities. According to HHS
officials, the timeframe for organizing the sector and setting up an
expanded Food ISAC has not been determined, but officials anticipated
this occurring by fall of 2004.
* Department of Agriculture (USDA). As mentioned above, USDA shares
with HHS the sector-specific agency designation for the food sector.
USDA participated in a conference held last summer and a recent meeting
with the industry. In addition to those events, USDA's Homeland
Security Council Working Group is involved in enhancing the agriculture
sector's information-sharing and analysis efforts, which may include
replacing or improving the current Food ISAC. Another USDA effort uses
training to reach out to the industry and raise awareness. For example,
USDA is providing training to private-sector veterinarians and animal
hospitals on recognizing possible signs of bioterrorism activity.
Although no longer a sector-specific agency for the transportation
sector, DOT, through its Federal Transit Administration, has provided a
grant to the Public Transportation ISAC to provide for memberships at
no cost.
Challenges to ISAC Establishment and Partnership with the Federal
Government:
Our discussions with the ISACs and the series of ISAC Council white
papers confirmed that a number of challenges remain to the successful
establishment and operation of ISACs and their partnership with DHS and
other federal agencies. Highlighted below are some of the more
significant challenges identified, along with any successful ISAC
practices and related actions that have been taken or planned by DHS or
others.
Increasing Sector Participation and Reach:
Many of the ISACs report that they represent significant percentages of
their industry sectors; at least one--the Electricity ISAC--reports
participation approaching 100 percent. The ISAC Council estimates that
the overall ISAC community possess an outreach and connectivity
capability to reach approximately 65 percent of the private critical
infrastructure. The Council also recognizes the challenge of increasing
sector participation, particularly to reach smaller entities that need
security support, but have insufficient resources to actively
contribute and pay for such support. Officials in DHS's IAIP
acknowledge the importance of reaching out to critical infrastructure
entities, and are considering alternatives to address this issue.
The Financial Services ISAC provides a notable example of efforts to
respond to this challenge. Specifically, officials for this
organization reported that, as of March 2003, its members represented a
large portion of the sector's assets, but only 0.2 percent of the
number of entities with small financial services firms and insurance
companies, in particular, were underrepresented. To increase its
industry membership, this organization established its next generation
ISAC, which provides different levels of service--ranging from a free
level of basic service to fees for value-added services--to help ensure
that no entity is excluded because of cost. Further, it has set goals
of delivering urgent and crisis alerts to 80 percent of the Banking and
Finance sector by the end of 2004 and to 99 percent of the sector by
the end of 2005. To help achieve these goals, the Financial Services
ISAC has several other initiatives under way, including obtaining the
commitment of the Financial Services Sector Coordinating Council
(FSSCC--the sector coordinator and primary marketing arm for this ISAC)
to drive the marketing campaign to sign up its members for the
appropriate tier of service; encourage membership through outreach
programs sponsored by the Federal Deposit Insurance Corporation and the
FSSCC in 24 cities; and to work with individual sector regulators to
include in their audit checklists whether a firm is a member of the
ISAC. The Financial Services ISAC believes that its goals are
attainable and points to its industry coverage, which it says had
already increased to 30 percent in March 2004--only three months after
its new membership approach began in December 2003.
Other issues identified that were related to increasing sector
participation and reach included the following,
* Officials at two of the ISACs we contacted considered it important
that the federal government voice its support for the ISACs as the
principal tool for communicating threats.
* The ISAC Council has suggested that a General Business ISAC may need
to be established to provide baseline security information to those
general businesses that are not currently supported by an ISAC.
* Many of the industries that comprise our nation's critical
infrastructures are international in scope. Events that happen to a
private infrastructure or public sector organization in another country
can have a direct effect in the United States, just as events here
could have effects in other countries. Therefore, an ISAC may need to
increase its reach to include the reporting and trust of international
companies and organizations.
Building Trusted Relationships:
A key element in both establishing an ISAC and developing an effective
public/private partnership for CIP is to build trusted relationships
and processes. From the ISAC perspective, sharing information requires
a trusted relationship between the ISAC and its membership, such that
companies and organizations know their sensitive data is protected from
others, including competitors and regulatory agencies. According to the
ISAC Council, the ISACs believe that they provide a trusted
information-sharing and analysis mechanism for private industry in that
they manage, scrutinize, establish, and authenticate the identity and
ensure the security of their membership, as well as ensuring the
security of their own data and processes. Other steps taken by ISACs to
safeguard private companies' information, which may help to foster
trusted relationships, included sharing information with other entities
only when given permission to do so by the reporting entity and
providing other protections, such as distributing sensitive information
to subscribers through encrypted e-mail and a secure Web portal.
Building trusted relationships between government agencies and the
ISACs is also important to facilitating information sharing. In some
cases, establishing such relationships may be difficult because sector-
specific agencies may also have a regulatory role; for example, the
Environmental Protection Agency has such a role for the Water sector
and HHS' Food and Drug Administration has it for portions of the Food
and Agriculture sectors.
Information Sharing Between the Private Sector and Government:
Sharing information between the federal government and the private
sector on incidents, threats, and vulnerabilities continues to be a
challenge. As we reported last year, much of the reluctance by ISACs to
share information has focused on concerns over potential government
release of that information under the Freedom of Information Act,
antitrust issues resulting from information sharing within an industry,
and liability for the entity that discloses the information.[Footnote
7] However, our recent discussions with the ISACs--as well as the
consensus of the ISAC Council--identified additional factors that may
affect information sharing by both the ISACs and the government.
The ISACs we contacted all described efforts to work with their sector-
specific agencies, as well as with other federal agencies, ISACs, and
organizations. For example, the Public Transit ISAC said that it
provides a critical link between the transit industry, DOT, TSA, DHS,
and other ISACs for critical infrastructures and that it collects,
analyzes, and distributes cyber and physical threat information from a
variety of sources, including law enforcement, government operations
centers, the intelligence community, the U.S. military, academia, IT
vendors, the International Computer Emergency Response Community, and
others. Most ISACs reported that they believed they were providing
appropriate information to the government but, while noting
improvements, still had concerns with the information being provided to
them by DHS and/or their sector-specific agencies. These concerns
included the limited quantity of information and the need for more
specific, timely, and actionable information. In particular, one ISAC
noted that it receives information from DHS simultaneously with or even
after news reports, and that sometimes the news reports provide more
details.
In its recent white papers, the ISAC Council also has identified a
number of barriers to information sharing between the private sector
and government. These included the sensitivity of the information (such
as law enforcement information), legal limits on disclosure (such as
Privacy Act limitations on disclosure of personally identifiable
information), and contractual and business limits on how and when
information is disclosed (e.g., the Financial Services ISAC does not
allow any governmental or law enforcement access to its database). But
the Council also emphasized that perhaps the greatest barriers to
information sharing stem from practical and business considerations in
that, although important, the benefits of sharing information are often
difficult to discern, while the risks and costs of sharing are direct
and foreseeable. Thus, to make information sharing real, it is
essential to lower the practical risks of sharing information through
both technical means and policies, and to develop internal systems that
are capable of supporting operational requirements without interfering
with core business. Consequently, the technical means used must be
simple, inexpensive, secure, and easily built into business processes.
According to the Council, the policy framework must reduce perceived
risks and build trust among participants. Further, the Council
identified three general areas that must be addressed in policy for the
information-sharing network to assure network participants that there
is good reason to participate and that their information will be dealt
with appropriately. These areas concern policies related to what
information is shared within ISACs, across ISACs, and to and from
government; actions to be performed at each node in the information-
sharing network, including the kinds of analysis to be performed; and
the protection of shared information and analysis in terms of both
limitations on disclosure and use and information security controls.
The white papers also described the processes that are believed to be
needed to ensure that critical infrastructure and/or security
information is made available to the appropriate people with reasonable
assurance that it cannot be used for malicious purposes or
indiscriminately redistributed so as to become essentially public
information. These processes and other information-sharing
considerations and tasks identified by the Council included the
following:
* The ISAC information-sharing process needs to recognize two types of
information categories--classified and sensitive but unclassified.
However, the majority of information sharing must focus on the
unclassified "actionable element" that points the recipient to a
problem and to remediation action.
* Each ISAC is responsible for initially validating the trust
relationship with its member organizations and for periodically
reassessing that trust relationship. The security structure must
understand and continually be in dialogue with its vetted members and
must manage this trusted relationship.
* Each individual who receives shared information must have a
background check completed by and at a level of comprehensiveness
specified by the sponsoring organization.
* Consequences and remediation must be developed and understood to
address situations in which information is disclosed improperly--either
intentionally or unintentionally.
* The government's data and information requirements for the sectors
and the sectors' requirements for the government need to be defined.
* The government should establish a standing and formal trusted
information-sharing and analysis process with the ISACs and sector
coordinators as the trusted nodes for this dissemination. This body
should be brought in at the beginning of any effort, and DHS products
should be released to this group for primary and priority dissemination
to their respective sectors.
Building this trusted information-sharing and analysis process is also
dependent on the protections the government provides for the sensitive
data shared by ISACs and private companies. As discussed earlier, DHS
recently issued the interim rule for submitting protected critical
infrastructure information, which provides restrictions on the use of
this information and exempts it from release under the Freedom of
Information Act. However, it remains to be seen whether these
protections will encourage greater private-sector trust and information
sharing with the federal government.
Identifying Roles and Responsibilities:
Federal CIP law and policies, including the Homeland Security Act of
2002, the National Strategy to Secure Cyberspace, and HSPD-7, establish
CIP responsibilities for federal agencies, including DHS and others
identified as sector-specific agencies for the critical infrastructure
sectors. However, the ISACs believe that the roles of the various
government and private-sector entities involved in protecting critical
infrastructures must continue to be identified and defined. In
particular, officials for several ISACs wanted a better definition of
the role of DHS with respect to them. Further, officials for two ISACs
thought other agencies might more appropriately be their sector-
specific agencies. Specifically, the Energy ISAC would like its sector-
specific agency to be DHS and not the Department of Energy, which is
also the regulatory agency for this sector. On the other hand, the
Highway ISAC thought its sector-specific agency should be the
Department of Transportation--the regulatory agency for its sector--and
not DHS.
The ISAC Council also identified the need for DHS to establish the
goals of its directorates and the relationships of these directorates
with the private sector. The Council also wants clarification of the
roles of other federal agencies, state agencies, and other entities--
such as the National Infrastructure Advisory Council.
Obtaining Government Funding:
Ten of the ISACs we contacted, plus the Healthcare sector, emphasized
the importance of government funding for purposes including creating
the ISAC, supporting operations, increasing membership, developing
metrics, and providing for additional capabilities. According to ISAC
officials, some have already received federal funding: the Public
Transit ISAC initially received a $1.2 million grant from the Federal
Transit Administration to begin operations, and the Water ISAC received
a $2 million grant from EPA for fiscal year 2004 to cover annual
operating costs and expand memberships to smaller utilities. In
addition, the Financial Services ISAC received $2 million from the
Department of the Treasury to help establish its next-generation ISAC
and its new capabilities, including adding information about physical
threats to the cyber threat information it disseminates.
Despite such instances, funding continues to be an issue, even for
those that have already received government funds. For example, the
Healthcare Sector Coordinating Council, which is the sector coordinator
for the healthcare industry, is currently looking to the federal
government to help fund the creation of a Healthcare ISAC. Also,
officials at the Public Transit ISAC noted that funding is an ongoing
issue that is being pursued with DHS. Officials at the Financial
Services ISAC, who notes that the ISAC's goal is to become totally
self-funded through membership fees by 2005, are also seeking
additional government funding for other projects.
The ISAC Council has also suggested that baseline funding is needed to
support core ISAC functionalities and analytical efforts within each
sector. The Council's suggestions include that the government should
procure a bulk license for the ISACs to receive data directly from some
vulnerability and threat sources and access to analytical or modeling
tools and that the funding for an ISAC analyst to work at DHS to
support analysis of sector-specific information or intelligence
requirements.
According to the Financial Services ISAC, DHS has agreed to fund
tabletop exercises for some ISACs. For example, according to DHS
officials, exercises are occurring this week involving the Banking and
Finance sector and exercises for other sectors are currently being
explored. In addition, energy sector-related exercises were held
earlier in the year. DHS officials also stated that funding
considerations for the critical infrastructure sectors and the ISACs
would be based on their needs.
Utilizing Sector Expertise:
In our discussions with ISAC officials, several, such as officials from
the Surface Transportation and the Telecommunications ISACs,
highlighted their analysis capabilities and, in particular, their
analysts' sector-specific knowledge and expertise and ability to work
with DHS and other federal agencies. The ISAC Council also emphasized
that analysis by sector-specific, subject matter experts is a critical
capability for the ISACs, intended to help identify and categorize
threats and vulnerabilities and then identify emerging trends before
they can affect critical infrastructures. Sector-specific analysis can
add critical value to the information being disseminated, with products
such as 24/7 immediate, sector-specific, physical, cyber, all threat
and incident report warning; sector-specific information and
intelligence requirements; forecasts of and mitigation strategies for
emerging threats; and cross-sector interdependencies, vulnerabilities,
and threats.
The Council also emphasized that although government analytical efforts
are critical, private-sector analytical efforts should not be
overlooked and must be integrated into the federal processes for a more
complete understanding. The private sector understands its processes,
assets, and operations best and can be relied upon to provide the
required private-sector subject matter expertise.
In a few cases, the integration of private-sector analytical
capabilities with DHS does occur. For example, the Telecommunications
ISAC, as part of DHS's National Communication System, has watch
standers that are part of the DHS operations center and share
information, when the information owner allows it and when it is
appropriate and relevant, with the other analysts. In addition, a
Surface Transportation ISAC analyst also participates in the DHS
operations center on a part-time basis to offer expertise and
connection to experts in the field in order to clarify the impact of
possible threats.
Participation in National Homeland Security Exercises:
The ISAC Council highlighted the need for ISAC participation in the
national-level homeland security exercises that are conducted by the
federal government, such as DHS's May 2003 national terrorism exercise
(TOPOFF 2), which was designed to identify vulnerabilities in the
nation's domestic incident management capability. However, according to
the Council, there has been little or no integration of active private
industry and infrastructure into such exercises. For example, private
industry participation in TOPOFF 2 was simulated. The Council believes
that with such participation, both national and private-sector goals
could be established during the creation of the exercise and then
addressed during the exercise.
The Council did identify examples where the private sector is being
included in exercises, such as efforts by the Electronics Crime Unit of
the U.S. Secret Service to reach out to the private sector and support
tabletop exercises to address the security of private infrastructures.
Further, according to a DHS official, the department has agreed to fund
tabletop exercises for members of several ISACs, including Financial
Services, Chemical, and Electricity, as well as a cross-sector tabletop
exercise.
Additional Challenges:
Additional challenges identified by our work and/or emphasized by the
ISAC Council included the following.
* Obtaining Security Clearances to Share Classified Information. As we
reported last year, several ISACs identified obtaining security
clearances as a challenge to government information sharing with the
ISACs. Seven of the 15 ISACs with which we discussed this issue
indicated either that some of their security clearances were pending or
that additional clearances would be needed.
* Identifying Sector Interdependencies. Federal CIP policy has
emphasized the need to identify and understand interdependencies
between infrastructure sectors. The ISAC Council also highlighted the
importance of identifying interdependencies and emphasized that they
require partnerships between the sectors and the government and could
only be modeled, simulated, or "practiced" once the individual sectors'
dynamics are understood sufficiently. The current short-term focus for
the ISACs is to review the work done by the government and the sectors
regarding interdependencies. Similarly, a DHS official acknowledged the
importance of identifying interdependencies, but that it is a longer-
term issue.
* Establishing Communications Networks. Another issue raised through
the ISAC Council's white papers was the need for a government-provided
communications network for secure information sharing and analysis.
Specifically, the Council suggested that although functionality would
be needed to satisfy the ISAC s' requirements, DHS's Critical
Infrastructure Warning Information Network (CWIN) could be used as an
interim, first-phase communications capability. According to the
Council, some of the ISACs are conducting routine communications checks
at the analytical level in anticipation of expanded use of CWIN. In
discussing this issue with a DHS official, he said that ISAC access to
a secure communications network would be provided as part of the
planned Homeland Security Data Network (HSDN). DHS recently announced a
contract to initiate the implementation of HSDN, which is be a private,
certified, and accredited network that provides DHS officials with a
modern IT infrastructure for securely communicating classified
information. According to DHS, this network will be designed to be
scalable in order to respond to increasing demands for the secure
transmission of classified information among government, industry, and
academia to help defend against terrorist attacks.
DHS Information-Sharing Plan:
At the time of our study, the relationship and interaction among DHS,
the ISACs, sector coordinators, and other sector-specific agencies was
still evolving, and DHS had not yet developed any documented policies
or procedures. As we discussed earlier, HSPD-7 requires the Secretary
of Homeland Security to establish uniform policies for integrating
federal infrastructure protection and risk management activities within
and across sectors. According to a DHS official, the department is
developing a plan (referred to as a "roadmap") that documents the
current information-sharing relationships among DHS, the ISACs, and
other agencies; goals for improving that information-sharing
relationship; and methods for measuring the progress in the
improvement. According to this official, the plan is to define the
roles and responsibilities of DHS, the ISACs, and other entities,
including a potential overlap of ISAC-related responsibilities between
IAIP and the Transportation Security Administration. Further, the
official indicated that, in developing the plan, DHS would consider
issues raised by the ISAC Council.
In summary, since first encouraged by federal CIP policy almost 6 years
ago, private-sector ISACs have developed and evolved into an important
facet of our nation's efforts to protect its critical infrastructures.
They face challenges in increasing their sector representation and, for
some, ensuring their long-term viability. But they have developed
important trust relationships with and between their sectors--trust
relationships that the federal government could take advantage of to
help establish a strong public/private partnership. Federal agencies
have provided assistance to help establish the ISACs, and more may be
needed. However, at this time, the ISACs and other stakeholders,
including sector-specific agencies and sector coordinators, would
benefit from an overall strategy, as well as specific guidance, that
clearly described their roles, responsibilities, relationships, and
expectations. DHS is beginning to develop a strategy, and in doing so,
it will be important to consider input from all stakeholders to help
ensure that a comprehensive and trusted information-sharing process is
established.
Messrs. Chairmen, this concludes my statement. I would be happy to
answer any questions that you or members of the subcommittees may have
at this time.
If you should have any questions about this testimony, please contact
me at (202) 512-3317 or Ben Ritt, Assistant Director, at (202) 512-
6443. We can also be reached by e-mail at daceyr@gao.gov and
rittw@gao.gov, respectively.
Other individuals making key contributions to this testimony included
William Cook, Joanne Fiorino, Michael Gilmore, Barbarol James, Lori
Martinez, and Kevin Secrest.
FOOTNOTES
[1] The White House, The National Strategy to Secure Cyberspace
(Washington, D.C.: February 2003); The National Strategy for the
Physical Protection of Critical Infrastructures and Key Assets
(Washington, D.C.: February 2003); and Homeland Security Presidential
Directive 7, Critical Infrastructure Identification, Prioritization,
and Protection (Washington, D.C.: Dec. 17, 2003).
[2] The National Cyberspace Security Response System is a public/
private architecture, coordinated by the Department of Homeland
Security, for analyzing and warning; managing incidents of national
significance; promoting continuity in government systems and private-
sector infrastructures; and increasing information sharing across and
between organizations to improve cyberspace security. It includes
governmental entities and nongovernmental entities, such as private-
sector ISACs.
[3] The American Chemistry Council represents the leading companies
engaged in the business of chemistry. CHEMTREC® (Chemical
Transportation Emergency Center) is the American Chemistry Council's
24-hour emergency communications center. It was established in 1971 to
provide emergency responders technical assistance in safely mitigating
a distribution incident.
[4] The North American Electric Reliability Council's (NERC) membership
includes small and large electric utilities, regional utility
companies, power marketers, and other entities responsible for power
generation, transmission, control, and marketing and distribution in
the United States, Canada, and a portion of Mexico.
[5] The National Coordinating Center for Telecommunications is open to
companies that provide telecommunications or network services,
equipment, or software to the communications and information sector;
select, competitive local exchange carriers; Internet service
providers; vendors; software providers; telecommunications
professional organizations and associations; or companies with
participation or presence in the communications and information sector.
Membership is also allowed for National Coordinating Center member
federal departments and agencies, and for national security/emergency
preparedness users.
[6] CWIN provides connectivity and 24x7 alert and notification
capability to government and industry participants. It is engineered to
provide a reliable and survivable network capability, and it has no
logical dependency on the Internet or the Public Switched Network.
[7] U.S. General Accounting Office, Critical Infrastructure Protection:
Efforts of the Financial Services Sector to Address Cyber Threats,
GAO-03-173 (Washington, D.C.: Jan. 30, 2003); and Critical
Infrastructure Protection: Challenges for Selected Agencies and
Industry Sectors, GAO-03-233 (Washington, D.C.: Feb. 28, 2003).
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security
Washington, DC 20528:
Homeland Security:
June 24, 2004:
Mr. Robert F. Dacey:
Director, Information Security Service Services
U.S. General Accounting Office:
441 G St., NW
Washington, DC 20548:
Dear Mr. Dacey:
RE: GAO 04-780: Critical Infrastructure Protection Improving
Information Sharing with Infrastructure Sectors (Job Code #310519):
Thank you for the opportunity to review and comment on GAO Draft
Report, Critical Infrastructure Protection: Improving Information
Sharing With Infrastructure Sectors (GAO 04-780). We believe that this
report is well written, and generally provides an accurate analysis of
the current sector and Information Sharing and Analysis Center (ISAC)
landscape. We have forwarded a number of technical comments, under
separate cover, which we believe will add value to and improve the
accuracy of this report. In addition to those comments we have the
following more significant comments about the report:
The document should reference the Homeland Security Act of 2002:
The ISACs do not mitigate risk nor respond to events--sector owners and
operators do.
Information presented about the status of the agriculture and
healthcare sectors is outdated. The agriculture sector has been working
to integrate its efforts with the food sector, which currently has an
ISAC. The healthcare sector already is organized and has been
evaluating options on how to develop an information sharing mechanism;
the sector has deferred this discussion pending greater clarification
and direction from DHS.
The report states "...for fiscal year 2004 this agency issued a $2
million grant to the Water ISAC to enhance its capabilities--to fund
24X7 operations and to increase and support ISAC membership." Although
this has not been granted yet, it is in the Environmental Protection
Agency's FY 2004 budget to support information sharing.
DHS has informed Congress of our plans to develop a timeline this
summer for a "roadmap" that documents the current information-sharing
relationships among DHS, the ISACs, and other agencies; goals for
improving that information-sharing relationship; and methods for
measuring the progress in the improvement.
Again, we appreciate the opportunity to comment on this report. If you
have any questions regarding our comments, contact John V. Daley, IAIP
Audit Liaison at 202-282-8381.
Sincerely,
Signed by:
Anna F. Dixon
Enclosure:
Comments on Recommendations contained in General Accounting Office
Report on "Critical Infrastructure Protection: Improving Information
Sharing with Infrastructure Sectors" (GAO-04-780).
Recommendation:
Proceed with and establish milestones for the development of an
information-sharing plan that includes (1) a clear description of the
roles and responsibilities of DHS, the ISACs, sector coordinators, and
the sector-specific agencies and (2) actions designed to address
information-sharing challenges. Efforts to develop this plan should
include soliciting feedback from the ISACs sector coordinators, and
sector-specific agencies to help ensure that challenges identified by
the ISACs and the ISAC Council are appropriately considered in the
final plan.
Planned Actions:
This recommendation affirms initiatives already begun by IAIP to
provide clarity on roles and responsibilities for information sharing
and to address information sharing challenges. The ISAC Council has
developed several white papers, whose contents we have reviewed and
taken into consideration. The National Infrastructure Protection Plan
(NIPP), required by HSPD-7, will address roles and responsibilities.
The CI Information Sharing Roadmap Project is intended to work directly
with the sectors to assess and solidify requirements. It is estimated
to begin in July, 2004 and targeted to complete most of its work second
quarter, 2005:
Recommendation:
Considering the roles, responsibilities, and actions established in the
information-sharing plan, develop appropriate DHS policies and
procedures for interacting with ISACs, sector coordinators, and sector-
specific agencies and for coordination and information sharing within
the IAIP Directorate (such as the National Cyber Security Division and
Infrastructure Coordination Divisio ) and other DHS components that may
interact with the ISACs, including TSA.
Planned Actions:
The recommendation affirms the current intensive activities in DHS to
develop programmatic poli'cy and standard operating procedures in
conjunction with implementing its operational capabilities, such as the
National Infrastructure Coordination Center, in the Infrastructure
Coordination Division, and among work units within DHS. We intend to
adapt procedures as the NIPP and the Cl Information Sharing Roadmap
evolves.
[End of section]
Appendix III: Comments from the Department of Health and Human
Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
JUN 28, 2004:
Mr. Robert F. Dacey:
Director, Information Security Issues
United States General Accounting Office
Washington, D.C. 20548:
Dear Mr. Dacey:
The Department has reviewed your draft report entitled, "Critical
Infrastructure Protection: Improving Information Sharing with
Infrastructure Sectors" (GAO-04-780) and has no comments at this time.
The Department provided technical comments directly to your staff.
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Dara Corrigan:
Acting Principal Deputy Inspector General:
The Office of Inspector General (OIG) is transmitting the Department's
response to this draft report in our capacity as the Department's
designated focal point and coordinator for General Accounting Office
reports. OIG has not conducted an independent assessment of these
comments and therefore expresses no opinion on them.
[End of section]
Appendix IV: Comments from the Department of the Treasury:
UNDER SECRETARY:
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
June 22, 2004:
Mr. Ben Ritt:
Assistant Director, Information Security Issues
U.S. General Accounting Office:
Room 4T21:
441 G Street NW
Washington, D.C. 20548:
Dear Mr. Ritt:
The Department of the Treasury submits the following comments to the
draft report entitled Critical Infrastructure Protection: Improving
Information Sharing with Infrastructure Sectors (GAO-04-780).
On page 11, GAO refers to Federal Deposit Insurance Corporation (FDIC)
sponsored outreach briefings that address "why the private sector needs
to partner with the federal government to improve its security." The
FDIC does exemplary work to make these events possible; two entities
not mentioned in this report, the Financial and Banking Infrastructure
Information Committee and the Financial Services Coordinating Council
for Critical Infrastructure Protection and Homeland Security, formed
under the auspices of the Department of the Treasury also participate
in and sponsor these events. These organizations are a wonderful
example of the broad partnerships the Treasury Department has formed to
improve information sharing across the finance and banking sector.
Overall, we agree with the conclusions of this report.
Sincerely,
Signed by:
Brain C. Roseboro:
Under Secretary for Domestic Finance:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Ben Ritt (202) 512-6443:
Staff Acknowledgments:
In addition to the individual named above, William Cook, Joanne
Fiorino, Laurence Gill, Michael Gilmore, Barbarol James, Lori Martinez,
and Kevin Secrest made key contributions to this report.
(310519):
FOOTNOTES
[1] Homeland Security Act of 2002, P.L. 107-296 (Nov. 25, 2002).
[2] U.S. General Accounting Office, Critical Infrastructure Protection:
Establishing Effective Information Sharing with Infrastructure
Sectors, GAO-04-699T (Washington, D.C.: Apr. 21, 2004).
[3] Eleven ISACs created an ISAC Council to improve the ISACs'
efficiency and effectiveness. It works on various operational, process,
and other common issues to effectively analyze and disseminate
information and, where possible, to leverage the work of the entire
ISAC community.
[4] The Homeland Security Act of 2002 designated five undersecretaries,
among other entities, with responsibility over directorates for
management, science and technology, information analysis and
infrastructure protection, border and transportation security, and
emergency preparedness and response.
[5] The Financial and Banking Information Infrastructure Committee
coordinates federal and state financial regulatory efforts to improve
the reliability and security of U.S. financial systems. The Financial
Services Sector Coordinating Council's mission is to foster and
facilitate the coordination of financial services sector-wide voluntary
activities and initiatives designed to improve critical infrastructure
protection and homeland security.
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