Critical Infrastructure Protection
Further Efforts Needed to Integrate Planning for and Response to Disruptions on Converged Voice and Data Networks
Gao ID: GAO-08-607 June 26, 2008
Technological advances have led to an increasing convergence of previously separate networks used to transmit voice and data communications. While the benefits of this convergence are enormous, such interconnectivity also poses significant challenges to our nation's ability to respond to major disruptions. Two operations centers--managed by the Department of Homeland Security's (DHS) National Communications System and National Cyber Security Division--plan for and monitor disruptions on voice and data networks. In September 2007, a DHS expert task force made three recommendations toward establishing an integrated operations center that the department agreed to adopt. To determine the status of efforts to establish an integrated center, GAO reviewed documentation, interviewed relevant DHS and private sector officials, and reviewed laws and policies to identify DHS's responsibilities in addressing convergence.
DHS has taken the first of three steps toward integrating its centers that are responsible for planning for, monitoring, and responding to disruptions to the communications infrastructure, including voice and data networks, and the security of data and applications that use these networks. Specifically, in November 2007, it moved the operations center for communications infrastructure (NCC Watch) to office space adjacent to the center for data and applications (US-CERT). This close proximity allows the approximately 41 coordination center and 95 readiness team analysts to, among other things, readily collaborate on planned and ongoing activities. In addition, the centers have jointly acquired common software tools to identify and share physical, telecommunications, and cyber information related to performing their missions. For example, the centers use one of the tools to develop a joint "morning report" specifying their respective network security issues and problems, which is used by the analysts in coordinating responses to any resulting disruptions. While DHS has completed the first integration step, it has yet to implement the remaining two steps. Specifically, although called for in the task force's recommendations, the department has not organizationally merged the two centers or invited key private sector critical infrastructure officials to participate in the planning, monitoring, and other activities of the proposed joint operations center. A key factor contributing to DHS's lack of progress in implementing the latter two steps is that completing the integration has not been a top DHS priority. Instead, DHS officials stated that their efforts have been focused on other initiatives, most notably the President's recently announced cyber initiative, which is a federal governmentwide effort to manage the risks associated with the Internet's nonsecure external connections. Nevertheless, DHS officials stated that they are in the process of drafting a strategic plan to provide overall direction for the activities of the National Communications System and the National Cyber Security Division. However, the plan is in draft and has been so since mid-2007. In addition, DHS officials could not provide a date for when it would be finalized. Consequently, the department does not have a strategic plan or related guidance that provides overall direction in this area and has not developed specific tasks and milestones for achieving the two remaining integration steps. Until DHS completes the integration of the two centers, it risks being unable to efficiently plan for and respond to disruptions to communications infrastructure and the data and applications that travel on this infrastructure, increasing the probability that communications will be unavailable or limited in times of need.
Recommendations
Our 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.
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GAO-08-607, Critical Infrastructure Protection: Further Efforts Needed to Integrate Planning for and Response to Disruptions on Converged Voice and Data Networks
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Report to the Subcommittee on Emerging Threats, Cybersecurity, and
Science and Technology, Committee on Homeland Security, House of
Representatives:
United States Government Accountability Office:
GAO:
June 2008:
Critical Infrastructure Protection:
Further Efforts Needed to Integrate Planning for and Response to
Disruptions on Converged Voice and Data Networks:
GAO-08-607:
GAO Highlights:
Highlights of GAO-08-607, a report to the Subcommittee on Emerging
Threats, Cybersecurity, and Science and Technology, Committee on
Homeland Security, House of Representatives.
Why GAO Did This Study:
Technological advances have led to an increasing convergence of
previously separate networks used to transmit voice and data
communications. While the benefits of this convergence are enormous,
such interconnectivity also poses significant challenges to our
nation‘s ability to respond to major disruptions. Two operations
centers”managed by the Department of Homeland Security‘s (DHS) National
Communications System and National Cyber Security Division”plan for and
monitor disruptions on voice and data networks. In September 2007, a
DHS expert task force made three recommendations toward establishing an
integrated operations center that the department agreed to adopt. To
determine the status of efforts to establish an integrated center, GAO
reviewed documentation, interviewed relevant DHS and private sector
officials, and reviewed laws and policies to identify DHS‘s
responsibilities in addressing convergence.
What GAO Found:
DHS has taken the first of three steps toward integrating its centers
that are responsible for planning for, monitoring, and responding to
disruptions to the communications infrastructure, including voice and
data networks, and the security of data and applications that use these
networks. Specifically, in November 2007, it moved the operations
center for communications infrastructure (NCC Watch) to office space
adjacent to the center for data and applications (US-CERT). This close
proximity allows the approximately 41 coordination center and 95
readiness team analysts to, among other things, readily collaborate on
planned and ongoing activities. In addition, the centers have jointly
acquired common software tools to identify and share physical,
telecommunications, and cyber information related to performing their
missions. For example, the centers use one of the tools to develop a
joint ’morning report“ specifying their respective network security
issues and problems, which is used by the analysts in coordinating
responses to any resulting disruptions.
While DHS has completed the first integration step, it has yet to
implement the remaining two steps. Specifically, although called for in
the task force‘s recommendations, the department has not
organizationally merged the two centers or invited key private sector
critical infrastructure officials to participate in the planning,
monitoring, and other activities of the proposed joint operations
center. A key factor contributing to DHS‘s lack of progress in
implementing the latter two steps is that completing the integration
has not been a top DHS priority. Instead, DHS officials stated that
their efforts have been focused on other initiatives, most notably the
President‘s recently announced cyber initiative, which is a federal
governmentwide effort to manage the risks associated with the
Internet‘s nonsecure external connections. Nevertheless, DHS officials
stated that they are in the process of drafting a strategic plan to
provide overall direction for the activities of the National
Communications System and the National Cyber Security Division.
However, the plan is in draft and has been so since mid-2007. In
addition, DHS officials could not provide a date for when it would be
finalized. Consequently, the department does not have a strategic plan
or related guidance that provides overall direction in this area and
has not developed specific tasks and milestones for achieving the two
remaining integration steps.
Until DHS completes the integration of the two centers, it risks being
unable to efficiently plan for and respond to disruptions to
communications infrastructure and the data and applications that travel
on this infrastructure, increasing the probability that communications
will be unavailable or limited in times of need.
What GAO Recommends:
GAO is recommending that the Secretary of Homeland Security complete
(1) its strategic plan and (2) define tasks and milestones for
completing remaining integration steps. DHS concurred with GAO‘s first
recommendation. With regard to the second, DHS stated it supports
integrating overlapping functions, but does not support merging the
centers. However, there is strong evidence supporting the need to merge
the centers to enhance incident response.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-607]. For more
information, contact David A. Powner at (202) 512-9286 or
pownerd@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DHS Has Completed the First of Its Three-Step Integration Approach, but
Has Yet to Implement the Remaining Steps:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objective, Scope, and Methodology:
Appendix II: Critical Infrastructure Sectors:
Appendix III: Comments from the Department of Homeland Security:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Critical Infrastructure Sectors and Designated Sector-Specific
Agencies:
Figure:
Figure 1: Packet Switching vs. Circuit Switching:
Abbreviations:
DHS: Department of Homeland Security:
IT: information technology:
NCC Watch: National Coordination Center Watch:
NCC: National Coordination Center:
NCS: National Communications System:
NCSD: National Cyber Security Division:
US-CERT: U.S. Computer Emergency Readiness Team:
[End of section]
United States Government Accountability Office: Washington, DC 20548:
June 26, 2008:
The Honorable James R. Langevin:
Chairman:
The Honorable Michael T. McCaul:
Ranking Member:
Subcommittee on Emerging Threats, Cybersecurity, and Science and
Technology: Committee on Homeland Security:
House of Representatives:
Effective voice and data networks and the information traveling on them
are essential to our ability as a nation to maintain public health and
safety during a catastrophic natural disaster, such as a hurricane, or
a man-made event, such as a terrorist attack. Technological advances in
these networks have led to an increasing consolidation of previously
separate voice and data networks into converged "next generation"
networks that are capable of transmitting both voice and data on a
single network. Federal policies assign two Department of Homeland
Security (DHS) components--the National Cyber Security Division (NCSD)
and the National Communications System (NCS)--responsibilities for
planning for and facilitating our nation's response to major
disruptions on the communications infrastructure, including voice and
data networks.
In April 2007, DHS established a task force of subject matter experts
to study, among other things, whether there were opportunities to merge
NCSD and NCS operations. In September 2007, the task force made three
recommendations aimed at integrating aspects of NCSD and NCS
operations, namely those responsible for preparing for and responding
to network disruptions. DHS accepted the recommendations and, in doing
so, adopted a high-level approach for integrating the operations that
included the following steps:
* collocating the operations center of the national communications
system that oversees the communications infrastructure, including voice
and data networks--namely, the National Coordination Center Watch (NCC
Watch) with the operations center of the NCSD that oversees the
security of data and applications that use the communications
infrastructure--called the U.S. Computer Emergency Readiness Team (US-
CERT);
* developing an integrated operations center by merging NCC-Watch and
US-CERT; and:
* inviting private sector critical infrastructure officials to
participate in the planning, monitoring, and other activities of the
new operations center.
In response to your request, our objective was to determine the status
of efforts to integrate NCSD and NCS activities to prepare for and
respond to disruptions on converged voice and data networks. To
accomplish this, we reviewed DHS documentation and interviewed DHS
officials. To determine how these components were addressing
convergence issues, we interviewed private sector stakeholders to
obtain their perspectives on DHS's efforts to address convergence and
reviewed laws and policies to identify DHS's responsibilities in
addressing convergence. We conducted our work in the Washington, D.C.
metropolitan area, from September 2007 to June 2008 in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. Details on our objective,
scope, and methodology are in appendix I.
Results in Brief:
DHS has taken the first of three steps toward integrating its centers
responsible for planning for and monitoring the communications
infrastructure, including voice and data networks, and the security of
data and applications residing on these networks. Specifically, in
November 2007, it moved the operations center for communications
infrastructure--NCC Watch--to office space adjacent to the center for
data and applications--US-CERT. This close proximity allows the
approximately 41 coordination center and 95 readiness team analysts to,
among other things, readily collaborate on planned and ongoing
activities. In addition, the centers have jointly acquired common
software tools to identify and share physical, telecommunications, and
cyber information related to performing their missions. For example,
the centers use one of the tools to develop a joint "morning report"
specifying their respective security issues and problems, which is used
by the analysts in coordinating responses to any resulting disruptions.
While DHS has completed this first integration step, it has yet to
implement the other two. Specifically, the department has not
organizationally merged the two centers or invited key private sector
critical infrastructure officials to participate in the operation of
the proposed joint center. DHS's lack of progress on the latter steps
is attributable, in part, to it not making integration a top DHS
priority. Instead, its management efforts have been focused on other
priorities, such as the President's recently announced cyber
initiative. DHS officials stated that they are in the process of
drafting a strategic plan to provide overall direction for the
activities of NCS and NCSD, including completing the integration of the
centers. However, the plan is in draft and has been so since mid-2007.
In addition, DHS officials could not provide a date for when it would
be finalized. Consequently, the department does not have a strategic
plan or related guidance that provides overall direction in this area
and has not developed specific tasks and milestones for achieving the
remaining two integration steps.
Until DHS completes the integration of the two centers, it risks being
unable to efficiently plan for and respond to disruptions to
communications infrastructure and the data and applications that reside
on this infrastructure, increasing the probability that communications
will be unavailable or limited in times of need. Accordingly, we are
recommending that the Secretary of DHS complete its strategic plan for
NCSD and NCS and define the specific tasks and milestones for
completing the remaining integration steps.
In commenting on a draft of this report, the department agreed with our
first recommendation and did not support our second recommendation.
With regard to the second recommendation, DHS stated that, while it
supports further integration of overlapping functions, it does not
support organizationally merging the centers at this time and added
that the lack of a merger will not impact its ability to respond to
incidents. We do not agree. To the contrary, there is strong evidence
that DHS's ability to respond is negatively impacted by the use of
separate centers, rather than a single integrated and merged entity.
Our past work has shown that overlapping roles for incident response
have adversely affected DHS's ability to prioritize and coordinate
incident response activities.
Background:
An effective communications infrastructure, including voice and data
networks, is essential to our ability as a nation to maintain public
health and safety during a catastrophic natural disaster, such as a
hurricane, or a man-made event, such as a terrorist attack.
Technological advances in these networks have led to a convergence of
the previously separate networks used to transmit voice and data
communications. These new networks--next generation networks--are
capable of transmitting both voice and data on a single network and
eventually will be the primary means for voice and data transmissions.
Converged voice and data networks have many benefits. For example,
these networks use technology based on packet switching, which allows
greater resiliency. Packet switching involves breaking a message into
packets, or small chunks of data, and transferring the packets across a
network to a destination where they are recombined. The resiliency of
using a packet-switching network is due to the packet's ability to be
transmitted over multiple routes, avoiding areas that may be congested
or damaged. Conversely, conventional voice services use traditional
telephone networks, which are based on circuit switching technology.
Instead of breaking a message up into packets, circuit-switching uses a
dedicated channel to transmit the voice communication. Once all of the
channels are occupied, no further connections can be made until a
channel becomes available. Figure 1 shows a comparison between packet
switching and circuit switching.
Figure 1: Packet Switching vs. Circuit Switching:
[See PDF for image]
This figure contains illustrations of Packet Switching vs. Circuit
Switching, as follows:
Packet-switched network:
Original message: Mr. Watson, Come here. I need you.
Broken into packets;
Routed across a network path that can be modified as needed;
Reassembled to form original message.
Circuit-switched network:
Original message: Mr. Watson, Come here. I need you.
Broken into packets;
Routed across a fixed network path;
Reassembled to form original message.
Source: GAO analysis; Art Explosion (images).
[End of figure]
Converged networks, however, also pose certain technical challenges.
For example, current national programs to provide priority voice
services in an emergency are based primarily on voice or traditional
telephone networks, which are circuit-switched. Implementing these
networks on packet-switched networks is difficult because there is no
uniformly accepted standard for providing priority service on a packet-
switched network. Also, the Internet-based protocols used on packet-
switched networks have vulnerabilities and in certain cases, packet-
switched networks may be unreliable for emergency communications due to
delays in transmission and loss of packets.
Federal Policies Provide for Critical Infrastructure Protection for
Communications:
Federal policies[Footnote 1] call for the protection of essential
public and private infrastructures, such as the electric power grid,
chemical plants, and water treatment facilities that control the vital
functions critical to ensuring our national economic security and
public health and safety. These infrastructures, called critical
infrastructures, also include communications infrastructure, such as
voice and data communication networks. Federal policies also designate
certain federal agencies as lead points of contact for each key
critical infrastructure sector and assign responsibility for
infrastructure protection activities and for coordination with other
relevant federal agencies, state and local governments, and the private
sector. (See app. II for a description of the sectors and the
designated federal agencies.) DHS is the lead federal agency for both
the telecommunications and information technology (IT) sectors. DHS is
also designated as the focal point for the security of cyberspace--
including analysis, warning, information sharing, vulnerability
reduction, mitigation, and recovery efforts for public and private
critical infrastructure information systems.
As part of its responsibilities, DHS created the National
Infrastructure Protection Plan[Footnote 2] to coordinate the protection
efforts of critical infrastructures. The plan recognizes the Internet
as a key resource composed of assets within both the IT and the
telecommunications sectors. It notes that the Internet is used by all
critical infrastructure sectors to varying degrees and that it provides
information and communications to meet the needs of businesses,
government, and the other sectors. The National Infrastructure
Protection Plan requires lead federal agencies for the critical
infrastructure sectors to work with public and private sector
stakeholders to develop sector-specific plans that address how the
sectors' stakeholders will improve the security of their assets,
systems, networks, and functions. We recently reported[Footnote 3] on
how comprehensively these sector-specific plans address the cyber
security aspects of their sectors, including the plans for the IT and
telecommunications sectors. We found that the plans varied in how
sector stakeholders identified their cyber risks and developed plans to
identify, respond to, and recover from a cyber attack. Accordingly, we
recommended specific measures to help DHS strengthen the development,
uniformity, and use of the plans.
DHS's Office of Cyber Security and Communications Is Responsible for
Both Cyber and Telecommunications Security and Recovery:
Federal policies[Footnote 4] provide DHS the lead responsibility for
facilitating a public-private response to disruptions to major
communications infrastructure, such as voice and data networks. Within
DHS, the responsibility is assigned to NCSD and NCS in the Office of
Cyber Security and Communications. NCSD has responsibility for the
security of data and applications and executes this duty via its
operations center--US-CERT--while NCS has responsibility for the
communications infrastructure that carries data and applications and
carries out its duty through its coordination center, NCC, and its
operations center, NCC Watch.
National Cyber Security Division:
In June 2003, DHS created NCSD to serve as the national focal point for
addressing cyber security issues. NCSD's mission is to secure
cyberspace and America's cyber assets in cooperation with public,
private, and international entities. The division carries out its
mission via its US-CERT operations center, which is responsible for,
among other things, analyzing and addressing cyber threats and
vulnerabilities and disseminating cyber-threat warning information. In
the event of a security issue or disruption affecting data and
applications, US-CERT is to facilitate coordination of recovery
activities with the network and security operations centers of owners
and operators of these networks and with government officials (e.g.,
incident response teams) responsible for protecting government
networks. NCSD is the government lead on a public/private partnership
supporting US-CERT and serves as the lead for the federal government's
cyber incident response through the National Cyber Response
Coordination Group. This group is the principal federal interagency
mechanism for coordinating the preparation for and response to
significant cyber incidents, such as a major Internet disruption, and
includes members from 19 federal departments and agencies.[Footnote 5]
National Communications System:
NCS is responsible for ensuring that communications infrastructure used
by the federal government is available under all conditions--ranging
from normal situations to national emergencies and international
crises. The system does this through several activities, including a
program that gives calling priority to federal executives, first
responders, and other key officials in times of emergency. NCS was
established by presidential direction[Footnote 6] in August 1963 in
response to voice communication failures associated with the Cuban
Missile Crisis. Its role was further clarified through an executive
order[Footnote 7] issued in April 1984 that established the Secretary
of Defense as the executive agent for NCS. In 2003, it was transferred
to the responsibility of the Secretary of DHS.[Footnote 8]
NCS is composed of members from 24 federal departments and agencies.
Although it originally focused on "traditional" voice services via
common carriers, NCS has now taken a larger role in Internet-related
issues due to the convergence of voice and data networks. For example,
it now helps manage issues related to disruptions of the Internet
backbone (e.g., high-capacity data routes). NCC, which serves as the
coordination component of NCS, is the point of contact with the private
sector on issues that could affect the availability of the
communications infrastructure. According to DHS, the center includes 47
members from major telecommunications organizations, such as Verizon
and AT&T. These members represent 95 percent of the wireless and wire
line telecommunications service providers and 90 percent of the
Internet service provider backbone networks.
During a major disruption in telecommunications services, NCC Watch is
to coordinate with NCC members in an effort to restore service as soon
as possible. In the event of a major Internet disruption, it is to
assist recovery efforts through its partnerships and collaboration with
telecommunications and Internet-related companies. Using these
partnerships, NCC has also created several programs that, in times of
emergency, provide calling priority in to enable first responders and
key officials at all levels to communicate using both landline phones
and cellular devices.
Federal and Private Sector Experts Have Recommended a More Integrated
Approach to Planning for and Responding to Disruptions on Converged
Networks:
Since February 2002, we, along with federal government and private
sector experts, have examined the convergence of voice and data
networks into next generation networks. All these experts recommend
that federal agencies such as DHS adopt an integrated approach--
including integrating their organizations--to planning for and
responding to network disruptions.[Footnote 9] In February 2002, before
the formation of DHS, a White House advisory group recommended that the
federal government develop such an approach.[Footnote 10] Specifically,
it found that timely information sharing was essential to effective
incident response, that existing coordination within the government was
ineffective and needed senior management attention, and that NCS should
broaden its capabilities to include more IT industry expertise.
In March 2006, the National Security Telecommunications Advisory
Committee, a presidential advisory group, also recommended that DHS
develop an integrated approach to incident response on next generation
networks and update priority communications programs to improve
existing recovery abilities.[Footnote 11] The committee recommended
that DHS establish an inclusive and effective incident response
capability that includes functions of the NCC and a broadened
membership, including firms in the IT sector. The committee also stated
that most new communications providers are not members of the NCC, were
not easily accessible during an incident, and had not yet developed
close working relationships with other industry stakeholders and the
federal government.
In June 2006, we recommended that DHS improve its approach to dealing
with disruptions by examining the organizational structure of NCSD and
NCS in light of the convergence of voice and data networks. We found
that DHS had overlapping responsibilities for incident response, which
affected the ability of DHS to prioritize and coordinate incident
response activities.[Footnote 12]
Furthermore, in December 2006, the Telecommunications and Information
Technology Information Sharing and Analysis Centers, composed of
representatives of private telecommunications and IT companies, sent a
letter to DHS asking that the department develop a plan to integrate
critical infrastructure protection efforts including planning for and
responding to disruptions. In a January 2007 written response signed by
the Assistant Secretary for Cyber Security and Communications, DHS
agreed with the importance of this effort and stated that developing a
road map for integration was a priority.
Moreover, in April 2007, the two information sharing and analysis
centers established a task force (referred to as a "tiger team" by DHS)
with DHS that, among other things, identified overlapping
responsibilities between NCC Watch and US-CERT in the following areas:
[Footnote 13]
* developing and disseminating warnings, advisories, and other urgent
notifications;
* evaluating the scope of an event;
* facilitating information sharing;
* deploying response teams during an event;
* integrating cyber, communications, and emergency response exercises
into operational plans and participation; and:
* the management of relationships with others, such as industry
partners.
Consequently, the tiger team task force recommended merging the two
centers to establish an integrated operations center and further
recommended that DHS adopt a three-step approach to integration of the
centers. The approach should include:
* moving NCC Watch to office space physically adjacent to US-CERT;
* developing an integrated operations center by merging US-CERT and NCC
Watch, and:
* inviting private sector critical infrastructure officials to join
this new center.
In addition to these three steps, the task force also recommended
specific actions to be taken in implementing them. For example, in
developing an integrated operations center by merging NCC Watch and US-
CERT, the task force recommended, among other things, that DHS (1)
appoint a project manager to lead this effort; (2) develop policies and
procedures that integrate operations and address overlapping
responsibilities, including how the new center is to respond in an
integrated manner to threats and incidents; and (3) establish
performance measures to monitor progress. In addition, with regard to
involving key private sector critical infrastructure officials in the
new center, the task force recommended that the department also appoint
a project manager to lead this effort. This effort would include
seeking participation of appropriate private sector officials,
identifying any potential legal issues to having these officials serve
in the new center, and developing measures to monitor progress.
In September 2007, DHS approved the report, accepting the
recommendations and adopting the three-step approach.
DHS Has Completed the First of Its Three-Step Integration Approach, but
Has Yet to Implement the Remaining Steps:
DHS has taken the first of three steps toward integrating NCSD and NCS
by moving the two centers, NCC Watch and US-CERT, to adjacent office
space in November 2007. This close proximity allows the approximately
41 coordination center and 95 readiness team analysts to, among other
things, readily collaborate on planned and ongoing activities. In
addition, the centers have jointly acquired common software tools to
identify and share physical, telecommunications, and cyber information
related to performing their missions. For example, the centers use one
of the tools to develop a joint "morning report" specifying their
respective security issues and problems, which is used by the analysts
in coordinating responses to any resulting disruptions.
While DHS has completed the first step, it has yet to implement the
remaining two steps and supporting actions. Specifically, the
department has not organizationally merged or integrated operation
centers or completed any of the supporting actions. For example, the
department has not hired a project manager, developed common operating
procedures, or established progress measures. In addition, according to
DHS officials, they have no efforts planned or underway to implement
this step and associated actions.
With regard to involving key private sector officials to participate in
the proposed joint center,[Footnote 14] the department has not
accomplished this step and supporting actions either. For example, it
has not hired a project manager or sought participation of appropriate
private sector officials to work at the new center. DHS officials told
us they also have no efforts planned or underway to implement this step
and its supporting actions.
A key factor contributing to DHS's lack of progress in implementing
these steps is that completing the integration is not a top department
priority. Instead, DHS officials stated that their efforts have been
focused on other initiatives, most notably the President's recently
announced cyber initiative, which is a federal governmentwide effort to
manage the risks associated with the Internet's nonsecure external
connections. Officials from DHS's Office of Cyber Security and
Communications stated that they are in the process of drafting a
strategic plan to provide overall direction for the activities of NCS
and NCSD, including completing the integration of the centers. However,
the plan is in draft and has been so since mid-2007. In addition, DHS
officials could not provide a date for when it would be finalized.
Consequently, the department does not have a strategic plan or related
guidance that provides overall direction in this area and has not
developed specific tasks and milestones for achieving the remaining two
integration steps.
Until DHS completes the integration of these two centers, it risks
being unable to efficiently plan for and respond to disruptions to
communication infrastructure, including voice and data networks, and
the information traveling on these networks, increasing the probability
that communications will be unavailable or limited in times of need.
Conclusions:
While DHS has taken initial steps toward integrating the key centers
that plan for and respond to disruptions to the communications
infrastructure, including voice and data networks, and the data and
applications on these networks, these offices are still not fully
integrated as envisioned. Consequently, the risks associated with not
having a fully integrated response to disruptions to the communications
infrastructure remain. Effectively mitigating these risks will require
swift completion of the integration. To do this will also require
strong leadership to make the integration effort a department priority
and to managing it accordingly, including completing the strategic plan
and defining remaining integration tasks and milestones. To do less
will continue to expose the nation's communications networks to
continuing risk of inadequate response to an incident.
Recommendations for Executive Action:
We are making two recommendations to the Secretary of Homeland Security
to direct the Assistant Secretary for Cyber Security and Communications
to:
* Establish milestones for completing the development and
implementation of the strategic plan for NCSD and NCS.
* Define specific tasks and associated milestones for establishing the
integrated operations center through merging NCC Watch and US-CERT and
inviting and engaging key private sector critical infrastructure
officials from additional sectors to participate in the operations of
the new integrated center.
Agency Comments and Our Evaluation:
In written comments on a draft of this report (see app. III), signed by
the Acting Director of DHS's Departmental Liaison Office, the
department concurred with our first recommendation and stated it is
taking steps to implement it. Specifically, the department said that as
part of its effort to develop and implement a strategic plan, it
intends to take into consideration, among other things, the
recommendations of the various expert groups that have studied issues
confronting DHS in this area and the lessons learned from collocating
the two centers. Further, the department stated that this strategic
planning also is to provide for integrating the centers' existing
overlapping functions with the aim of increasing mission effectiveness.
With regard to our second recommendation, DHS stated that, while it
supports further integration of overlapping functions, it does not
support organizationally merging the centers at this point and added
that the lack of a merger will not impact its ability to respond to
incidents.
We do not agree. To the contrary, there is strong evidence that shows
that DHS's ability to respond is negatively impacted by the use of
separate centers, rather than a single integrated and merged entity.
Specifically, our past work has shown that overlapping responsibilities
for incident response have adversely affected DHS's ability to
prioritize and coordinate incident response activities. For example,
private-sector firms have reported that in responding to a critical
incident, DHS made time-consuming and duplicative requests for
information without identifying how this information would be
beneficial in helping respond to the event. In addition, the DHS-
commissioned expert task force on the subject recently reported that
without an organizationally integrated center, the department will not
have a comprehensive operating picture of the nation's cyber and
communications infrastructure and thus not be able to effectively
implement activities necessary to prepare, protect, respond, and
recover this infrastructure. Further, our interviews with private-
sector cyber and communications infrastructure executives performed as
part of this engagement found that they also favor a merged
organization that includes broad industry participation. This evidence
calls for DHS to take a closer look at the issue of whether to merge
the centers.
DHS also commented on the report's description of the roles and
responsibilities of NCC and US-CERT. Specifically, DHS noted that our
original characterization of NCC as dealing with voice systems and US-
CERT with data systems was not totally accurate. Instead, DHS offered
that a more accurate distinction would be that NCC deals with
communication infrastructure, including voice and data networks, and US-
CERT deals with the security of systems and data using the networks,
which DHS commonly refers to as cyber situational awareness and
response. We agree with this comment and have incorporated it in the
report where appropriate.
In addition to its written response, the department also provided
technical comments that we have incorporated in the report where
appropriate.
We will send copies of this report to interested congressional
committees, the Secretary of Homeland Security, and other interested
parties. In addition, this report will be available at no charge on
GAO's Web site at [hyperlink, http://www.gao.gov]. If you have any
questions on matters discussed in this report, please contact David A.
Powner at (202) 512-9286 or at pownerd@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix IV.
Signed by:
David A. Powner:
Director, Information Technology Management Issues:
[End of section]
Appendix I: Objective, Scope, and Methodology:
Our objective was to determine the status of Department of Homeland
Security (DHS) efforts to integrate the activities of its National
Cyber Security Division (NCSD) and National Communications System (NCS)
in preparing for and responding to disruptions in converged voice and
data networks.
To accomplish this, we first analyzed pertinent laws, policies, and
related DHS documentation (e.g., charters and mission statements)
showing the responsibilities of NCSD and NCS, particularly with regard
to the increasing convergence of voice and data networks. We also
analyzed key studies on DHS's approach to managing convergence. We did
this to identify key findings and recommendations pertinent to our
objective. In particular, we focused on the Industry-Government Tiger
Team Report and Recommendations for a Cyber Security and Communications
Joint Operations Center, which recommended establishing an integrated
operations center. DHS adopted the recommendations as part of its three-
step approach to establish such a capability by (1) moving the National
Coordination Center (NCC) Watch to office space physically adjacent to
the US Computer Emergency Readiness Team (US-CERT), (2) developing an
integrated operations center by merging NCC Watch and US-CERT, and (3)
inviting private sector critical infrastructure officials to
participate in this new center. We also interviewed DHS and industry
officials who served on the tiger team task force and developed the
report findings and recommendations.
To determine the status of DHS's efforts to integrate the centers, we
analyzed department progress against the three steps specified in DHS's
approach. We also obtained and analyzed plans and related documentation
from DHS on its status in establishing an integrated operations center
capability. In particular, we assessed department plans and related
documentation on the status of collocating and merging the NCS and NCSD
operations centers. In addition, we analyzed documentation on DHS's
status in inviting key private sector infrastructure officials to join
the operations of the new center. We also interviewed relevant
officials in these organizations, including the managers of the
National Coordination Center and the U.S. Computer Emergency Readiness
Team, the Director of NCS, and the Acting Director of NCSD, to get
their perspectives and to validate our understanding of their efforts
to date. We also interviewed private sector officials--including the
Chair of the Communications Information Sharing and Analysis Center and
the President and Vice President of the IT Information Sharing and
Analysis Center--to obtain their perspectives on DHS's progress in
addressing convergence, including establishing the integrated center
and to determine whether they had received DHS invitations to
participate in the operation of the integrated center.
Next, to identify gaps, we compared the state of DHS's progress against
the task force recommendations adopted by DHS as part of its three step
approach to integration. When gaps were identified, we also interviewed
responsible DHS officials to determine any causes and their impact.
We conducted this performance audit in the Washington, D.C.
metropolitan area from September 2007 to June 2008 in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
[End of section]
Appendix II: Critical Infrastructure Sectors:
Table 1: Critical Infrastructure Sectors and Designated Sector-Specific
Agencies:
Sector: Agriculture and food;
Sector-specific agency: Department of Agriculture, Department of Health
and Human Services, Food and Drug Administration[A].
Sector: Banking and finance;
Sector-specific agency: Department of the Treasury.
Sector: Chemical;
Sector-specific agency: Department of Homeland Security.
Sector: Commercial facilities;
Sector-specific agency: Department of Homeland Security.
Sector: Commercial nuclear reactors, materials, and waste;
Sector-specific agency: Department of Homeland Security.
Sector: Critical Manufacturing;
Sector-specific agency: Department of Homeland Security.
Sector: Dams;
Sector-specific agency: Department of Homeland Security.
Sector: Defense industrial base;
Sector-specific agency: Department of Defense.
Sector: Drinking water and water treatment systems;
Sector-specific agency: Environmental Protection Agency.
Sector: Emergency services;
Sector-specific agency: Department of Homeland Security.
Sector: Energy;
Sector-specific agency: Department of Energy.
Sector: Government facilities;
Sector-specific agency: Department of Homeland Security.
Sector: Information technology;
Sector-specific agency: Department of Homeland Security.
Sector: National monuments and icons;
Sector-specific agency: Department of the Interior.
Sector: Postal and shipping;
Sector-specific agency: Department of Homeland Security.
Sector: Public health and health care;
Sector-specific agency: Department of Health and Human Services.
Sector: Telecommunications;
Sector-specific agency: Department of Homeland Security.
Sector: Transportation systems;
Sector-specific agency: Department of Homeland Security.
Sources: The National Infrastructure Protection Plan, Homeland Security
Presidential Directive 7, and the National Strategy for Homeland
Security.
[A] The Department of Agriculture is responsible for food (including
meat, poultry, and eggs) and agriculture; and the Department of Health
and Human Services, Food and Drug Administration, is responsible for
food other than meat, poultry, and egg products.
[End of table]
[End of section]
Appendix III: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
[hyperlink, http://www.dhs.gov]:
Mr. David A. Powner:
Director:
Information Technology Management Issues:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Powner:
Thank you for the opportunity to review and comment on the Government
Accountability Office's (GAO's) Draft Report GAO-08-607 entitled
Critical Infrastructure Protection: Further Efforts Needed to Integrate
Planning for and Response to Disruptions on Converged Voice and Data
Networks. Technical comments have been provided under separate cover.
General Comments:
1. This GAO report deals with the issue of the convergence of the
communications and IT sectors by focusing primarily on the integration
of the National Communications System's (NCS) National Coordinating
Center (NCC) and the National Cyber Security Division's (NCSD) U.S.
Computer Emergency Readiness Team (US-CERT). The fundamental concern is
as technology converges into the Next Generation Network (NGN), this
network continues to support national security and emergency
preparedness (NS/EP) needs.
NCS and NCSD have established a variety of programs to ensure NS/EP
communications are available during crisis and disasters when the
general public's ability to communicate has been interrupted. The NCS
is working to ensure priority services continue as industry converts to
an Internet Protocol (IP) based transport network.
Current projections for NS/EP NGN priority voice over IP (VoIP) include
an Initial Operational Capability (IOC) in 2012 while projections for
NS/EP NGN broadband (data) priority services IOC is delayed due to
receiving less funding than requested in FY 2008. Until these priority
services are fielded, NS/EP priority voice and data communications over
next generation IP networks will be unavailable to support Continuity
of Government (COG) and Continuity of Operations (COOP) mission
critical applications in times of crisis. This represents a greater
risk to the ability of the Department to efficiently plan for and
respond to voice and data network disruptions.
2. Much of this GAO report accepts the September 2007 recommendations
of a "Tiger Team" to study the possibility of establishing a Cyber
Security & Communications (CS&C) Joint Operations Center. The Tiger
Team recommended merging US-CERT and NCC through a three-step approach.
Given the importance of collaboration, US-CERT and NCC acted quickly to
implement the fast step by co-locating their facilities in November
2007. The co-location has ensured close coordination and improved
information sharing between the two watches. The recent Estonia denial
of service attack illustrated the capability of the NCC and US-CERT to
jointly respond to an incident in an efficient and effective manner.
Co-locating these two centers has certainly increased the effectiveness
of each, and further integration of certain complementary functions
will likely yield better results. However, merging these two centers
organizationally is not a top priority for a number of operational
reasons:
* NCSD and NCS have focused time and resources on other initiatives,
such as the Comprehensive National Cyber Initiative and the NGN (see
General Comment #1 above).
* Although NCC and US-CERT have significant interdependencies which
will increase as voice and data technologies converge, they have
distinct missions, as described in General Comment #3 below.
* The increased coordination between the NCC and US-CERT has shown the
uniqueness of their functions. This GAO report cites a list of
overlapping responsibilities identified by the Tiger Team; however the
execution of these responsibilities has proved to be different in
several cases due to different subject matter, audiences, and missions
(see Technical Comments, GAO Report page 11).
* Workspace classification level is another distinction between the two
watches. US-CERT requires TS/SCI capability for its operations center,
while NCS must maintain an operating space at SECRET and unclassified
levels to coordinate with its industry partners. A merged watch would
still require separate spaces to perform all of the necessary
functions.
GAO's statement that without a merger, DHS risks not being able to
efficiently plan for and respond to voice and data network disruptions
is inaccurate. US-CERT and NCC have demonstrated through their
collaborative planning and operational processes that there is little
to no risk that a response cannot be planned and executed in limes of
need.
3. Throughout this report, the distinction between the NCC and the US-
CERT is made by characterizing NCC as dealing with voice systems and US-
CERT with data systems. This is not an accurate distinction. The
mission of the NCC, as established by Executive Order 12472, is to
assist in the initiation, coordination, restoration, and reconstitution
of NS/EP telecommunications services or facilities under all conditions
of crisis or emergency. Telecommunications services, as defined by the
Federal Communications Commission, is "the transmission, emission, or
reception of signals, signs, writing, images, sounds or intelligence of
any nature, by wire, cable, satellite, fiber optics, laser, radio,
visual or other electronic, electric, electromagnetic, or acoustically
coupled means, or any combination thereof." This clearly encompasses
more than just voice. A more accurate distinction between the NCC and
USCERT would be:
* NCC deals with communications infrastructure;
* US-CERT deals with cyber situational awareness and response.
To a large extent, the NCS deals with the infrastructure backbone and
NCSD deals with the data and applications that ride on that backbone.
This interdependence is illustrated by the fact that the internet
backbone is owned largely by NCC industry members. Both NCC and US-CERT
deal with all types of information transfer, whether it be voice, data,
or multimedia. Indeed, as we move towards the NGN, the distinction
between voice and data becomes less relevant. Certainly
interdependencies between communications infrastructure and cyber
security will increase and the collaboration between NCC and US-CERT
will create synergies and efficiencies, but there will always be a need
for two distinct functions: ensure communications infrastructure
supports NS/EP requirements and ensure the data and applications riding
that infrastructure are secure.
Recommendation 1:
* establish milestones for completing the development and
implementation of the strategic plan for NCSD and NCS, and:
Response:
The NCS and NCSD concur with this recommendation and are taking steps
to address it. However, the NCS and NCSD strategic plans, as an element
of the CS&C strategic plan, should take into consideration not only the
recommendations from the National Security Telecommunications Advisory
Committee and the Tiger Team, but also lessons learned since co-
locating NCC and USCERT in November 2007. Co-location has provided a
heightened awareness of the NCC's and USCERT's distinct missions and
operational requirements. The NCS and NCSD strategic plans should
provide vision for communication collaboration while integrating
overlapping functions that will increase the effectiveness of each
organization.
Recommendation 2:
* define specific tasks and associated milestones for establishing the
integrated operations center through merging NCC and US-CERT and
inviting and engaging key private sector critical infrastructure
officials to participate in the operations of the new integrated
center.
Response:
As discussed in the General Comments, NCSD and NCS have distinct
missions and operational requirements. Ensuring collaboration between
NCC and US-CERT is paramount to successful response to national events.
However, merging these two centers organizationally may not be
practical or efficient for a number of operational reasons. NCS and
NCSD support further integration of certain overlapping functions as
appropriate, but they do not support organizationally merging the NCC
and US-CERT at this time.
Thank you again for the opportunity to comment on this Draft Report and
we look forward to working with you on future homeland security issues.
Signed by:
Penelope G. McCormack:
Acting Director:
Departmental Audit Liaison Office:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
David A. Powner, (202) 512-9286 or pownerd@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Gary Mountjoy (Assistant
Director), Scott Borre, Camille Chaires, Neil Doherty, Vijay D'Souza,
Nancy Glover, Lee McCracken, and Jeffrey Woodward made key
contributions to this report.
[End of section]
Footnotes:
[1] Homeland Security Presidential Directive Number 7 (Washington,
D.C., December 2003), National Infrastructure Protection Plan
(Washington, D.C., June 2006), National Response Framework (Washington,
D.C., January 2008), and National Strategy to Secure Cyberspace
(Washington, D.C., February 2003).
[2] Department of Homeland Security, National Infrastructure Protection
Plan, (Washington, D.C., 2006).
[3] GAO, Critical Infrastructure Protection: Sector-Specific Plans'
Coverage of Key Cyber Security Elements Varies, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-113] (Washington, D.C.: Oct.
31, 2007).
[4] See, for example, National Strategy to Secure Cyberspace, the
National Infrastructure Protection Plan, the Cyber Incident Annex to
the National Response Framework, and Homeland Security Presidential
Directive 7.
[5] They are the Central Intelligence Agency; the Departments of
Agriculture, Commerce, Defense, Energy, Health and Human Services,
Homeland Security, Interior, Justice, State, Transportation, and the
Treasury; the Director of National Intelligence; the Environmental
Protection Agency; the Homeland Security Council; the National Security
Agency; the National Security Council; the National Counterintelligence
Executive; and the Office of Management and Budget.
[6] National Security Action Memorandum 252.
[7] Executive Order No. 12472, Section 1.e, April 3, 1984.
[8] Executive Order No. 12386, March 1, 2003.
[9] GAO, Internet Infrastructure: DHS Faces Challenges in Developing a
Public/Private Recovery Plan, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-672] (Washington, D.C.: June 16, 2006) and The
President's National Security Telecommunications Advisory Committee,
Next Generation Network Task Force Report (Washington, D.C., Mar. 28,
2006).
[10] White House Convergence Working Group, Impact of Network
Convergence on NS/EP Telecommunications: Initial Findings and FY02/FY03
Programmatic Recommendations Information Infrastructure Protection
Assurance Group (IIPAG) (Washington, D.C., July 2001).
[11] National Security Telecommunications Advisory Committee, Next
Generation Networks Task Force Report.
[12] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-672].
[13] Industry Telecommunication and IT Sector Representatives,
Government Tiger Team Report and Recommendations for a Cyber Security
and Communications Joint Operations Center (Washington D.C., September
2007).
[14] While officials from the telecommunications sector serve on the
NCC and private sector IT firms have relationships with US-CERT, the
tiger team task force recommended expanding membership of the new joint
operations center to include officials from the other 16 critical
infrastructure sectors.
[End of section]
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