Critical Infrastructure Protection
Challenges for Selected Agencies and Industry Sectors Gao ID: GAO-03-233 February 28, 2003The explosive growth of computer interconnectivity is transforming the workings of our nation, its government, and its critical infrastructures. But with the enormous benefits of this interconnectivity comes a threat: both physical and cyber assets are potentially vulnerable to computer-based attack. In response, Presidential Decision Directive 63 (PDD 63, May 1998) called for a range of actions to improve the nation's ability to detect and respond to serious infrastructure attacks. For specific agencies under the Committee on Energy and Commerce's jurisdiction and for private-sector organizations for which these agencies have responsibilities, GAO was asked, among other things, to assess their progress and challenges in undertaking critical infrastructure protection (CIP) activities.
Federal efforts to protect our nation's critical public and private infrastructures have had mixed progress. GAO examined four specific agencies--the Departments of Health and Human Services (HHS), Energy, and Commerce, and the Environmental Protection Agency (EPA)--and found that the agencies have made progress in implementing several PDD 63 requirements, such as appointing chief information assurance officers and preparing initial CIP plans. However, none of the agencies has fully implemented all requirements, including the fundamental processes of identifying agency assets that are critical to the nation and determining their dependencies on other public and private assets, as well as assessing these assets' vulnerabilities. In addition, although most agencies have tentatively identified their critical assets, these efforts could take years to complete given the current pace and estimated time and resource needs. GAO also examined private-sector groups known as Information Sharing and Analysis Centers (ISACs) for five specific industry sectors--information technology, telecommunications, energy, electricity, and water supply. PDD 63 suggested voluntary ISAC creation to, among other things, serve as mechanisms for information sharing between infrastructure sectors and the government. In response, ISACs have been established and are serving as clearinghouses for their sectors to share information. For other suggested activities, such as establishing baseline statistics on computer security incidents, progress is mixed. Both the agencies and the ISACs identified challenges and obstacles to undertaking CIP activities. Agency-identified challenges included coordinating security efforts for critical assets with the General Services Administration, which may often be responsible for protecting agency facilities that house critical assets. The ISACs identified obstacles to information sharing, both between the sectors and the government and within the sectors. In particular, they noted concerns that information reported to the government could be subject to public release under the Freedom of Information Act.
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-03-233, Critical Infrastructure Protection: Challenges for Selected Agencies and Industry Sectors
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Report to the Committee on Energy and Commerce, House of
Representatives:
February 2003:
Critical Infrastructure Protection:
Challenges for Selected Agencies and Industry Sectors:
GAO-03-233:
GAO Highlights:
Highlights of GAO-03-233, a report to the Committee on Energy and
Commerce, House of Representatives
Why GAO Did This Study:
The explosive growth of computer interconnectivity is transforming the
workings of our nation, its government, and its critical
infrastructures.
But with the enormous benefits of this interconnectivity comes a
threat:
both physical and cyber assets are potentially vulnerable to computer-
based attack. In response, Presidential Decision Directive 63 (PDD 63,
May 1998) called for a range of actions to improve the nation‘s ability
to detect and respond to serious infrastructure attacks. For specific
agencies under the Committee on Energy and Commerce‘s jurisdiction and
for private-sector organizations for which these agencies have
responsibilities, GAO was asked, among other things, to assess their
progress and challenges in undertaking critical infrastructure
protection
(CIP) activities.
What GAO Found:
Federal efforts to protect our nation‘s critical public and private
infrastructures have had mixed progress. GAO examined four specific
agencies”the Departments of Health and Human Services (HHS), Energy,
and
Commerce, and the Environmental Protection Agency (EPA)”and found that
the agencies have made progress in implementing several PDD 63
requirements, such as appointing chief information assurance officers
and
preparing initial CIP plans. However, none of the agencies has fully
implemented all requirements, including the fundamental processes of
identifying agency assets that are critical to the nation and
determining
their dependencies on other public and private assets, as well as
assessing these assets‘ vulnerabilities. In addition, although most
agencies have tentatively identified their critical assets, these
efforts
could take years to complete given the current pace and estimated
time and
resource needs. GAO also examined private-sector groups known as
Information Sharing and Analysis Centers (ISACs) for five specific
industry sectors”information technology, telecommunications, energy,
electricity, and water supply. PDD 63 suggested voluntary ISAC creation
to, among other things, serve as mechanisms for information sharing
between infrastructure sectors and the government. In response, ISACs
have been established and are serving as clearinghouses for their
sectors to share information. For other suggested activities, such as
establishing baseline statistics on computer security incidents (see
table below), progress is mixed.
Both the agencies and the ISACs identified challenges and obstacles to
undertaking CIP activities. Agency-identified challenges included
coordinating security efforts for critical assets with the General
Services Administration, which may often be responsible for protecting
agency facilities that house critical assets. The ISACs identified
obstacles to information sharing, both between the sectors and the
government and within the sectors. In particular, they noted concerns
that information reported to the government could be subject to public
release under the Freedom of Information Act.
What GAO Recommends:
GAO recommends that the agencies take steps to complete the
identification and analysis of their critical assets, including setting
milestones and developing plans to address vulnerabilities. GAO also
recommends that selected sectors‘ lead agencies assess the need for
public policy tools to encourage increased private-sector CIP
activities. In its comments on a draft of this report, HHS concurred
with recommended agency activities. Technical comments by other
agencies and private-sector entities were also addressed, as
appropriate.
www.gao.gov/cgi-bin/getrpt?GAO-03-233
To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Robert Dacey at (202) 512-3317 or
daceyr@gao.gov.
Letter:
Objectives, Scope, and Methodology:
Results in Brief:
Background:
Agencies Have Not Yet Completed Implementation of CIP Requirements:
ISACs‘ Progress in Implementing PDD 63-Suggested Activities Is Mixed:
Efforts to Improve Cooperation and Interaction with ISACs and
Assistance to Agencies Continue:
PDD 63 Implementation Presents Challenges and Obstacles:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Comments from the Department of Health and Human
Services:
Appendix II: GAO Contact and Staff Acknowledgements:
GAO Contact:
Acknowledgments:
Tables:
Table 1: Critical Infrastructure Lead Agencies and Sectors:
Table 2: Results of Agencies‘ Implementation of Selected PDD 63
Requirements:
Table 3: Tentative Results of Agencies‘ Efforts to Identify Their
Critical Assets:
Table 4: Status of Agency Vulnerability Assessments, as of December
2002:
Table 5: Critical Assets Included in Agencies‘ Continuity-of-
Operations/Continuity-of-Government Plans as of December 2002:
Table 6: Overview of Selected Information Sharing and Analysis Centers:
Table 7: Entities that Manage and Operate Selected Information Sharing
and Analysis Centers:
Table 8: ISACs‘ Progress in Performing Activities Suggested by PDD 63:
Table 9: Critical Infrastructure Spending by the Departments of
Commerce, Energy, and Health and Human Services and the Environmental
Protection Agency (Fiscal Years 2001-2003, Dollars in Millions):
Figures:
Figure 1: Information Security Incidents Reported to Carnegie-Mellon‘s
CERTŪ Coordination Center from 1995 through 2002:
Figure 2: Organizations with CIP Responsibilities, as Outlined by PDD
63:
Figure 3: Computer Security Weaknesses at 24 Major Federal Agencies:
Abbreviations:
CIAO: Critical Infrastructure Assurance Office:
CIO: chief information officer:
CIP: critical infrastructure protection:
DOD: Department of Defense:
ECIE: Executive Council on Integrity and Efficiency:
EPA: Environmental Protection Agency:
FBI: Federal Bureau of Investigation:
FOIA: Freedom of Information Act:
GISRA: Government Information Security Reform Legislation:
GSA: General Services Administration:
HHS: Department of Health and Human Services:
IG: inspector general:
ISAC: information sharing and analysis center:
NIPC: National Infrastructure Protection Center:
NIST: National Institute of Standards and Technology :
OMB: Office of Management and Budget:
PCIE: President‘s Council on Integrity and Efficiency :
PDD: Presidential Decision Directive:
SCADA: supervisory control and data acquisition:
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Letter February 28, 2003:
The Honorable W.J. ’Billy“ Tauzin
Chairman, Committee on Energy and Commerce
House of Representatives:
The Honorable John D. Dingell
Ranking Minority Member
Committee on Energy and Commerce
House of Representatives:
Since the early 1990s, an explosion in computer interconnectivity, most
notably growth in the use of the Internet, has revolutionized the way
that our government, our nation, and much of the world communicate and
conduct business. The benefits have been enormous. Vast amounts of
information are now literally at our fingertips, facilitating research
on virtually every topic imaginable; financial and other business
transactions can be executed almost instantaneously, often 24 hours a
day; and electronic mail, Internet Web sites, and computer bulletin
boards allow us to communicate quickly and easily with a virtually
unlimited number of individuals and groups. However, this widespread
interconnectivity also poses enormous risks to our computer systems
and, more important, to the critical operations and infrastructures
they support, such as telecommunications, power distribution, national
defense, law enforcement, and critical government services. Further,
private-sector entities control over 80 percent of our nation‘s
critical infrastructures. Because potential adversaries--be they
nation-states, cyberterrorist groups, criminal organizations, or
disgruntled insiders--can develop cyberattack capabilities to attempt
to exploit these risks, it is essential that our critical
infrastructures be adequately protected.
In response to these concerns, in May 1998 the President issued
Presidential Decision Directive 63 (PDD 63), which called for a range
of actions intended to improve federal agency security programs,
establish a partnership between the government and the private sector,
and improve the nation‘s ability to detect and respond to serious
computer-based or physical attacks. Such critical infrastructure
protection (CIP) activities 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. PDD 63 encouraged nonfederal participation,
including 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. The directive also
appointed lead federal agencies to work with specific industry sectors,
and it established several federal CIP entities, such as the Critical
Infrastructure Assurance Office (CIAO) within the Department of
Commerce, which was intended to, among other things, develop a national
plan for CIP, and the National Infrastructure Protection Center (NIPC),
an organization within the Federal Bureau of Investigation (FBI) that
was expanded to address national-level threat assessment, warning,
vulnerability, and law enforcement investigation and response.
In addition, on October 16, 2001, President Bush issued Executive Order
13231, ’Critical Infrastructure Protection in the Information Age,“
which continued many PDD 63 activities by focusing on cyberthreats to
critical infrastructures; the order also created the President‘s
Critical Infrastructure Protection Board to coordinate federal
cybersecurity efforts. On October 8, 2001, President Bush issued
Executive Order 13228, which created the Office of Homeland Security.
In addition, on November 25, 2002, the President signed the Homeland
Security Act of 2002 creating the Department of Homeland Security,
which, among other things, will consolidate certain CIP functions,
including assessing the vulnerabilities of and taking necessary
measures to protect the key resources and critical infrastructures of
the United States.
Objectives, Scope, and Methodology:
In response to your requests, our objectives were to:
* assess the pace and progress of efforts by the Departments of Health
and Human Services (HHS), Energy, and Commerce and by the Environmental
Protection Agency (EPA) to implement CIP requirements to protect their
own critical infrastructures and assets from cyber and physical
attacks, as prescribed by PDD 63 and Executive Orders 13231 and 13228;
* assess the progress of the private-sector ISACs established for the
information technology, telecommunications, energy, electricity, and
water-supply sectors in achieving the objectives of PDD 63 and
Executive Orders 13231 and 13228;
* assess the level of cooperation and interaction between these ISACs
and their federal lead agency counterparts, as well as the level of
assistance provided to the selected agencies by CIAO and NIPC and to
the ISACs by NIPC; and:
* identify any resource-related issues or other challenges or obstacles
that the selected agencies and ISACs indicate have affected their
efforts to implement the CIP requirements or objectives.
The agencies and ISACs selected for our review were specifically
requested by the House Committee on Energy and Commerce as consistent
with its jurisdiction for specific agencies and for the industry
sectors for which these agencies have responsibilities. We performed
this work at the four agencies--HHS, Energy, Commerce, and EPA--and for
the five ISACs associated with key sectors of our economy--
telecommunications, information technology, electricity, oil and gas
energy, and water supply. We also conducted our work at the national
CIAO within the Department of Commerce, the Department of Justice and
its NIPC, the General Services Administration, and the National
Communications System (an interagency body housed within and funded
through the Department of Defense).
To assess the pace and progress of efforts by the agencies to implement
requirements to protect their own critical infrastructures and assets,
we analyzed CIP plans and other documentation of efforts to implement
CIP requirements, including current results of their efforts to
identify critical assets using CIAO‘s Project Matrix methodology, where
available. Likewise, we evaluated selected vulnerability assessments to
determine the methodology used and whether they addressed specific
critical assets. We also met with agencies‘ chief information officers
or their staff, chief infrastructure assurance officers, and others
responsible for security of the agencies‘ cyber and physical assets to
determine their roles, responsibilities, and current activities. We did
not validate the accuracy of data provided in agencies‘ Project Matrix
reports, including their identification of critical assets and
vulnerability assessment data. Vulnerability assessments were often
physically maintained at the asset location and not readily available,
and agencies were also sometimes reluctant to share vulnerability
assessments because of their sensitive or classified nature.
To assess the progress and summarize the different management
structures and operating principles of private-sector ISACs established
for the information technology, telecommunications, energy,
electricity, and water-supply sectors, we collected and evaluated
relevant ISAC documents such as operational agreements, charters,
guidance, reporting requirements, summary incident statistics, and
vulnerability assessments. We also obtained and analyzed information
from ISAC officials regarding management structure, operating
principles, activities, challenges, obstacles, and level of cooperation
and interaction with federal agencies. We did not independently verify
information provided by ISAC representatives.
To determine the level of cooperation and interaction between these
ISACs and their federal counterparts, as well as the level of
assistance that CIAO, NIPC, or both provided to the selected agencies
or ISACs, we analyzed available documentation of efforts by CIAO and
NIPC to assist the four agencies, and we obtained the views of agency
officials about the extent of CIAO and NIPC assistance efforts. In
addition, we discussed with officials from Commerce, Energy, EPA, the
National Communications System, and NIPC the level of cooperation and
interaction between the ISACs and the applicable agencies. We also
discussed with ISAC officials the extent of cooperation and
interactions with federal agencies.
To determine the identity of any resource-related issues, challenges,
or obstacles that the agencies and ISACs indicate have affected their
efforts in implementing the CIP requirements or objectives, we analyzed
information on CIP budgets and expenditures that the agencies reported
to the Office of Management and Budget (OMB) as part of its national
security crosscut data call and that was included in OMB‘s June 2002
combating terrorism report to the Congress. We also analyzed agency
documentation on denials of CIP funding requests and obtained pertinent
views of agency officials on the adequacy of resources in meeting their
CIP responsibilities. We did not validate the accuracy of agency-
reported budget data. We also obtained the views of officials in the
four agencies and the ISACs on any other challenges or obstacles that
have affected their implementation of CIP requirements or objectives.
We conducted our review from March 2002 to February 2003 in accordance
with generally accepted government auditing standards.
Results in Brief:
All four agencies we reviewed have taken actions to implement federal
policy to protect their critical cyber and physical infrastructure from
attack, such as appointing a chief infrastructure assurance officer,
developing an initial CIP plan, and continuing to establish security
awareness and education programs and computer incident response
capabilities. However, over 4 years after PDD 63 was issued, the
agencies have still not completed the fundamental step of identifying
their critical infrastructure assets and the operational dependencies
of these vital assets on other public and private assets. Once these
assets and dependencies are identified, further steps will be
necessary, such as conducting or updating vulnerability assessments,
managing identified vulnerabilities, and ensuring that these assets are
appropriately considered in planning for the continuity of essential
agency operations. Three of the four agencies have tentatively
identified or are revisiting their critical assets, and all four are
working to complete this process. However, CIAO and agency estimates
show that just to identify the dependencies for one critical asset
could take hundreds of staff hours and as much as 6 to 7 months.
Further, according to CIAO officials, even its current efforts to
streamline the overall process may not require fewer resources to
identify asset dependencies. Neither the administration nor the
agencies have established specific deadlines or estimated the total
resource requirements to complete the asset and dependency
identification process, and completing these tasks at the current pace
could take years.
Although their basic operations were similar, the five ISACs we
reviewed all had different characteristics and had achieved different
levels of progress in undertaking the activities suggested by PDD 63.
For example, organizations have performed ISAC-related functions, such
as sharing computer security incident information and alerts, for the
telecommunications and electricity sectors for many years, whereas
ISACs for the information technology, water, and energy sectors were
only recently established. Also, some ISAC sponsors performed
operations in-house, and others hired private contractors to perform
these operations. The ISACs estimated different levels of industry
participation, which ranged from 60 to 70 percent for one to 90 percent
for another. For specific PDD 63-suggested activities, four of the five
reported that they had established baseline statistics on computer
security incidents, and although all stated that they served as the
clearinghouses for their own sectors, two reported that they did not
coordinate with other sectors. In addition, three of the five reported
that they make historical incident data available to industry partners
that have a ’need to know“ for CIP, but only one makes these data
available to the federal government.
Both NIPC and CIAO have provided assistance or information to assist
federal agencies in their efforts, and the lead agencies and NIPC have
assisted in establishing and operating ISACs. In commenting on their
relationship with NIPC, most of the ISACs reviewed were positive, but
they identified opportunities for improvement, such as the need for
more warnings and alerts and for providing those warnings on a timelier
basis. NIPC officials reported that they are working to address some of
these issues and that they have also signed information-sharing
agreements with ISACs that contain industry-specific cyber and physical
incident-reporting thresholds. Most of these ISACs also reported that
they were satisfied with the support they received from their lead
agencies.
The federal agencies and ISACs we reviewed identified a number of
challenges and obstacles to implementing national requirements and
objectives. From the agencies‘ perspective, these primarily involved
obtaining adequate funding and coordinating critical asset protection
efforts. ISAC-identified challenges and obstacles included a reluctance
to share incident information because of concerns that the government
would release it under the Freedom of Information Act and a concern
that information sharing within an industry could raise antitrust
issues. The recently enacted Homeland Security Act of 2002 includes
provisions that restrict federal, state, and local government use and
disclosure of critical infrastructure information that has been
voluntarily submitted to the Department of Homeland Security. However,
it is too early to tell whether such restrictions will improve
information sharing, and whether additional actions may be needed, such
as the use of public policy tools, to encourage increased private-
sector CIP efforts and information sharing with the federal government.
This report contains recommendations that the agencies take steps to
complete the identification and analysis of their critical assets and
their dependencies, including setting milestones, developing plans to
address vulnerabilities, and monitoring progress. This report also
contains recommendations that selected sectors‘ lead agencies assess
the need for public policy tools to encourage increased private-sector
CIP activities and greater sharing of intelligence and incident
information between industry sectors and the federal government.
The Department of Health and Human Services provided written comments
on a draft of this report (see app. I) and concurred with our
recommendations for executive agencies, noting that, in many cases, it
is already engaged in the recommended activities. We also received
written and oral technical comments from the Department of Commerce‘s
CIAO and its National Telecommunications and Information
Administration, EPA, HHS, the FBI, the National Communications System,
the North American Electric Reliability Council, the Association of
Metropolitan Water Agencies, and the Energy and Information Technology
ISACs. Comments from all these organizations have been incorporated
into the report, as appropriate.
Background:
As our reliance on our nation‘s critical infrastructures grows, so do
the potential threats and attacks that could disrupt critical
operations. PDD 63 outlined requirements for federal agencies and
suggested activities for the ISACs to encourage a strong partnership
between government and the private sector for CIP--requirements and
activities emphasized in more recent executive orders and national
strategies. PDD 63 calls for the protection of both cyber and physical
assets, and cyber CIP continues to be a key component of federal
information security efforts.
Incidents, Threats, and Potential Attack Consequences Are Significant:
The risks associated with our nation‘s reliance on interconnected
computer systems are substantial and varied. By launching attacks
across a span of communications systems and computers, attackers can
effectively disguise their identity, location, and intent, thereby
making them difficult and time-consuming to trace. Such attacks could
severely disrupt computer-supported operations, compromise the
confidentiality of sensitive information, and diminish the integrity of
critical data. A significant concern is that terrorists or hostile
foreign states could launch computer-based attacks on critical systems
to severely damage or disrupt national defense or other critical
operations or steal sensitive data, resulting in harm to the public
welfare.
The April 2002 report of the Computer Crime and Security Survey,
conducted by the Computer Security Institute and the FBI‘s San
Francisco Computer Intrusion Squad, showed that 90 percent of
respondents (primarily large corporations and government agencies) had
detected computer security breaches.[Footnote 1] In addition, the
number of computer security incidents reported to the CERTŪ
Coordination Center rose from 9,859 in 1999 to 52,658 in 2001 and
82,094 in 2002. And these are only the reported attacks. The Director,
CERT Centers, stated that he estimates that as much as 80 percent of
actual security incidents goes unreported, in most cases because (1)
the organization was unable to recognize that its systems had been
penetrated or there were no indications of penetration or attack, or
(2) the organization was reluctant to report. Figure 1 shows the number
of incidents reported to the CERT Coordination Center from 1995 through
2002.
Figure 1: Information Security Incidents Reported to Carnegie-Mellon‘s
CERTŪ Coordination Center from 1995 through 2002:
[See PDF for image]
[End of figure]
According to the National Security Agency, foreign governments already
have or are developing computer attack capabilities, and potential
adversaries are developing a body of knowledge about U.S. systems and
methods to attack these systems. In February 2002, the threat to these
infrastructures was highlighted by the Special Advisor to the President
for Cyberspace Security in a Senate briefing when he stated that
although to date none of the traditional terrorist groups, such as al
Qaeda, has used the Internet to launch a known assault on the
infrastructure of the United States, information on computerized water
systems was recently discovered on computers found in al Qaeda camps in
Afghanistan.[Footnote 2]
Further, in the aftermath of the terrorist attacks of September 11,
2001, there has been an increased recognition of the critical link
between cyberspace and physical space. In his November 2002
congressional testimony,[Footnote 3] the Director of the CERT Centers
at Carnegie-Mellon University noted that supervisory control and data
acquisition (SCADA) systems and other forms of networked computer
systems have been used for years to control power grids, gas and oil
distribution pipelines, water treatment and distribution systems,
hydroelectric and flood control dams, oil and chemical refineries, and
other physical systems, and that these control systems are increasingly
being connected to communications links and networks to reduce
operational costs by supporting remote maintenance, remote control, and
remote update functions. These computer-controlled and network-
connected systems are potential targets for individuals bent on causing
massive disruption and physical damage, and the use of commercial, off-
the-shelf technologies for these systems without adequate security
enhancements can significantly limit available approaches to protection
and may increase the number of potential attackers.
The September 11, 2001, attacks also raised concerns that potentially
disastrous cyberattacks could be coordinated to coincide with physical
terrorist attacks to maximize the impact of both. For example, NIPC has
warned that the potential for compound cyber and physical attacks,
referred to as ’swarming attacks,“ is an emerging threat to the U.S.
critical infrastructure.[Footnote 4] As NIPC reports, the effects of a
swarming attack include slowing or complicating the response to a
physical attack. For example, cyber attacks can be used to delay the
notification of emergency services and to deny the resources needed to
manage the consequences of a physical attack. A swarming attack could
also be used to worsen the effects of a physical attack. For instance,
a cyber attack on a natural gas distribution pipeline that opens safety
valves and releases fuels or gas in the area of a planned physical
attack could enhance the force of the physical attack. In addition, the
recently issued fourth annual report of the Advisory Panel to Assess
Domestic Response Capabilities for Terrorism Involving Weapons of Mass
Destruction concluded that the physical and cyber elements of CIP are
so intertwined that it makes no sense to address them
separately.[Footnote 5]
In its October 2002 report, an independent task force cochaired by
former Senators Gary Hart and Warren B. Rudman also highlighted the
importance of protecting our critical infrastructure from physical
attack, noting in particular that our homeland infrastructure for
refining and distributing energy to support our daily lives remains
largely unprotected against sabotage.[Footnote 6] In the report, the
task force warned that if the nation does not respond more urgently to
address its vulnerabilities, the next attack could result in even
greater casualties and widespread disruption to our lives and the
economy.
CIP Policy Has Been Evolving Since the Mid-1990s:
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. Over the years, a
variety of working groups have been formed, special reports written,
federal policies issued, and organizations created to address the
issues that have been raised. In October 1997, the President‘s
Commission on Critical Infrastructure Protection issued its
report,[Footnote 7] which described the potentially devastating
implications of poor information security for the nation. The report
recommended several measures to achieve a higher level of CIP,
including infrastructure protection through industry cooperation and
information sharing, a national organization structure, a revised
program of research and development, a broad program of awareness and
education, and reconsideration of laws related to infrastructure
protection. The report stated that a comprehensive effort would need to
’include a system of surveillance, assessment, early warning, and
response mechanisms to mitigate the potential for cyberthreats.“ It
said that the FBI had already begun to develop warning and threat
analysis capabilities and urged it to continue in these efforts. In
addition, the report noted that the FBI could serve as the preliminary
national warning center for infrastructure attacks and could provide
law enforcement, intelligence, and other information needed to ensure
the highest quality analysis possible.
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
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. The directive called on the federal government
to serve as a model of how infrastructure assurance is best achieved,
and it designated lead agencies to work with private-sector and
government organizations. Further, it established CIP as a national
goal and stated that, by the close of 2000, the United States was to
have achieved an initial operating capability to protect the nation‘s
critical infrastructures from intentional destructive acts and, no
later than 2003, an enhanced capability.
To accomplish its goals, PDD 63 designated and established
organizations to provide central coordination and support, including:
the Critical Infrastructure Assurance Office (CIAO), an interagency
office housed in the Department of Commerce, which was established to
develop a national plan for CIP on the basis of infrastructure plans
developed by the private sector and federal agencies;[Footnote 8]
* 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; and:
* the National Infrastructure Assurance Council, which was established
to enhance the partnership of the public and private sectors in
protecting our critical infrastructures.[Footnote 9]
To ensure coverage of critical sectors, PDD 63 also identified eight
private-sector infrastructures and five special functions. In addition,
for each of the infrastuctures and functions, the directive designated
lead federal agencies (known as sector liaisons) to work with their
counterparts in the private sector (known as sector coordinators). To
facilitate private-sector participation, PDD 63 also encouraged the
voluntary creation of ISACs that could serve as mechanisms for
gathering, analyzing, and appropriately sanitizing and disseminating
information to and from infrastructure sectors and the federal
government through NIPC. Figure 2 displays a high-level overview of the
organizations with CIP responsibilities, as outlined by PDD 63.
Figure 2: Organizations with CIP Responsibilities, as Outlined by PDD
63:
[See PDF for image]
Note: In February 2001, the Critical Infrastructure Coordination Group
was replaced by the Information Infrastructure Protection and Assurance
Group under the Policy Coordinating Committee on Counter-terrorism and
National Preparedness. In October 2001, the National Infrastructure
Assurance Council was replaced by the National Infrastructure Advisory
Council, and cyber CIP functions performed by the national coordinator
were assigned to the chair of the President‘s Critical Infrastructure
Protection Board.
[End of figure]
PDD 63 also called for a range of activities intended to establish a
partnership between the public and private sectors to ensure the
security of infrastructures essential to the operations of the
government and the economy. It required that the sector liaison and the
sector coordinator work with each other to address problems related to
CIP for their sector. In particular, PDD 63 required them to
(1) develop and implement a vulnerability awareness and education
program and (2) contribute to a sectoral National Infrastructure
Assurance Plan by:
* assessing the vulnerabilities of the sector to cyber or physical
attacks;
* recommending a plan to eliminate significant vulnerabilities;
* proposing a system for identifying and preventing major attacks; and:
* developing a plan for alerting, containing, and rebuffing an attack
in progress and then, in coordination with the Federal Emergency
Management Agency as appropriate, rapidly reconstituting minimum
essential capabilities in the aftermath of an attack.
Within the federal government, PDD 63 required every federal department
and agency to be responsible for protecting its own critical
infrastructure, including both cyber-based and physical assets. To
fulfill this responsibility, PDD 63 called for agencies‘ chief
information officers (CIOs) to be responsible for information
assurance, and it required every agency to appoint a chief
infrastructure assurance officer (who could also be the CIO) to be
responsible for the protection of all other aspects of an agency‘s
critical infrastructure. Further, it established the following
requirements specifically for or related to federal agencies‘
protection of their own critical infrastructures:
* develop, implement, and periodically update a plan for protecting its
critical infrastructure;
* determine its minimum essential infrastructure that might be a target
of infrastructure attack;
* conduct and periodically update vulnerability assessments of its
minimum essential infrastructure;
* develop a recommended remedial plan based on a vulnerability
assessment that identifies time lines for implementation,
responsibilities, and funding; and:
* analyze intergovernmental dependencies, and mitigate those
dependencies.
Other PDD 63 requirements for federal agencies are that they provide
vulnerability awareness and education to sensitize people regarding the
importance of security and to train them in security standards,
particularly regarding cybersystems; that they establish a system for
responding to a significant infrastructure attack while it is under
way, to help isolate and minimize damage; and that they establish a
system for rapidly reconstituting minimum required capabilities for
varying levels of successful infrastructure attacks.
In January 2000, the White House issued its National Plan for
Information Systems Protection.[Footnote 10] The national plan provided
a vision and framework for the federal government to prevent, detect,
respond to, and protect the nation‘s critical cyber-based
infrastructure from attack and reduce existing vulnerabilities by
complementing and focusing existing federal computer security and
information technology requirements. Subsequent versions of the plan
were expected to (1) define the roles of industry and state and local
governments working in partnership with the federal government to
protect physical and cyber-based infrastructures from deliberate attack
and (2) examine the international aspects of CIP.
In October 2001, President Bush signed Executive Order 13231,
establishing the President‘s Critical Infrastructure Protection Board
to coordinate cyber-related federal efforts and programs associated
with protecting our nation‘s critical infrastructures. The Special
Advisor to the President for Cyberspace Security chairs the board.
Executive Order 13231 tasks the board with recommending policies and
coordinating programs for protecting CIP-related information systems.
The executive order also established 10 standing committees to support
the board‘s work on a wide range of critical information infrastructure
efforts. The board is intended to coordinate with the Office of
Homeland Security in activities relating to the protection of and
recovery from attacks against information systems for critical
infrastructure, including emergency preparedness communications that
were assigned to the Office of Homeland Security by Executive Order
13228, dated October 8, 2001. According to Executive Order 13231, the
board recommends policies and coordinates programs for protecting
information systems for critical infrastructure, including emergency
preparedness communications and the physical assets that support such
systems. The Special Advisor reports to the Assistant to the President
for National Security Affairs and to the Assistant to the President for
Homeland Security. In addition, the chair coordinates with the
Assistant to the President for Economic Policy on issues relating to
private-sector systems and economic effects and with the Director of
OMB on issues relating to budgets and the security of federal computer
systems. Executive Order 13231 emphasized the importance of CIP and the
ISACs, but neither order identified additional requirements for
agencies to protect their critical infrastructures or suggested
additional activities for the ISACs.
In July 2002, the President issued the National Strategy for Homeland
Security to ’mobilize and organize our nation to secure the United
States homeland from terrorist attacks.“ According to the strategy, the
primary objectives of homeland security, in order of priority, are to
(1) prevent terrorist attacks within the United States, (2) reduce
America‘s vulnerability to terrorism, and (3) minimize the damage and
recover from attacks that do occur.[Footnote 11] In addition, the
strategy identifies critical infrastructure and intelligence and
warning (critical components of CIP) as two of its six mission areas.
It also identifies critical infrastructure sectors that require
protection against incapacitation and destruction, including many of
the sectors previously identified in PDD 63, such as information and
communications, energy, and water, as well as several new sectors,
including agriculture, food, chemical and hazardous materials, and
postal and shipping.[Footnote 12] The sectors and their lead agencies
are listed in table 1.
Table 1: Critical Infrastructure Lead Agencies and Sectors:
Lead agency: Homeland Security; Sectors: Information and
telecommunications; Transportation (aviation; rail; mass transit;
waterborne commerce; pipelines; and highways, including trucking and
intelligent transportation systems); Postal and shipping; Emergency
services; Continuity of government.
Lead agency: Treasury; Sectors: Banking and finance.
Lead agency: Health and Human Services; Sectors: Public health
(including prevention, surveillance, laboratory services, and personal
health services); Food (all except for meat and poultry).
Lead agency: Energy; Sectors: Energy (electrical power, oil and gas
production and storage).
Lead agency: Environmental Protection Agency; Sectors: Water; Chemical
industry and hazardous materials.
Lead agency: Agriculture; Sectors: Agriculture; Food (meat and
poultry).
Lead agency: Defense; Sectors: Defense industrial base.
Source: National Strategy for Homeland Security and PDD 63.
[End of table]
The Homeland Security Act of 2002 established the Department of
Homeland Security. Regarding CIP, the new department is responsible
for, among other things, (1) developing a comprehensive national plan
for securing the key resources and critical infrastructure of the
United States; (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; and (3) disseminating, as appropriate, information analyzed
by the department both within the department and to other federal
agencies, state and local government agencies, and private-sector
entities to assist in the deterrence, prevention, preemption of, or
response to terrorist attacks. To help accomplish these functions, the
act creates the Information Analysis and Infrastructure Protection
directorate within the new department and transfers 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) and CIAO. In addition,
as outlined in the National Strategy for Homeland Security, the new
department will become the lead agency for several industry sectors,
including information and telecommunications.
In addition to consolidation of CIP functions and responsibilities
within the Department of Homeland Security, the President‘s fiscal year
2004 budget request for this new department includes $829 million for
information analysis and infrastructure protection, a significant
increase from the estimated $177 million for fiscal year 2003. In
particular, funding requested for information analysis and
infrastructure protection includes about $500 million to identify key
critical infrastructure vulnerabilities and support the necessary steps
to ensure that security is improved at these sites. It also includes
almost $300 million for warning advisories, threat assessments, a
communications system, and outreach efforts to state and local
governments and the private sector.
The National Strategy for Homeland Security called for the Office of
Homeland Security and the President‘s Critical Infrastructure
Protection Board to complete cyber and physical infrastructure
protection plans, which would serve as the baseline for later
developing a comprehensive national infrastructure protection plan.
This strategy does not indicate a date when the comprehensive plan is
to be completed, but on February 14, 2003, the President released the
National Strategy to Secure Cyberspace and the complementary National
Strategy for the Physical Protection of Critical Infrastructures and
Key Assets.[Footnote 13]
The National Strategy to Secure Cyberspace is intended to provide an
initial framework for both organizing and prioritizing efforts to
protect our nation‘s cyberspace. It is also to provide direction to
federal departments and agencies that have roles in cyberspace
security, and to identify steps that state and local governments,
private companies and organizations, and individual Americans can take
to improve our collective cybersecurity. This strategy is organized
according to five national priorities, with major actions and
initiatives identified for each:
1. A National Cyberspace Security Response System--This system is
described as 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, in order to
improve cyberspace security. The system is to include governmental
entities and nongovernmental entities, such as private-sector ISACs.
Major actions and initiatives identified for cyberspace security
response include providing for the development of tactical and
strategic analysis of cyber attacks and vulnerability assessments;
expanding the Cyber Warning and Information Network to support the role
of the Department of Homeland Security in coordinating crisis
management for cyberspace security; coordinating processes for
voluntary participation in the development of national public-private
continuity and contingency plans; exercising cybersecurity continuity
plans for federal systems; and improving and enhancing public-private
information-sharing involving cyber attacks, threats, and
vulnerabilities.
2. A National Cyberspace Security Threat and Vulnerability Reduction
Program--This priority focuses on reducing threats and deterring
malicious actors through effective programs to identify and punish
them; identifying and remediating those existing vulnerabilities that,
if exploited, could create the most damage to critical systems; and
developing new systems with less vulnerability, and assessing emerging
technologies for vulnerabilities. Other major actions and initiatives
include creating a process for national vulnerability assessments, to
better understand the potential consequences of threats and
vulnerabilities; securing the mechanisms of the Internet by improving
protocols and routing; fostering the use of trusted digital control
systems/SCADA systems; understanding infrastructure interdependencies
and improving the physical security of cybersystems and
telecommunications; and prioritizing federal cybersecurity research
and development agendas.
3. A National Cyberspace Security Awareness and Training Program--This
priority emphasizes the promotion of a comprehensive national awareness
program to empower all Americans--businesses, the general workforce,
and the general population--to secure their own parts of cyberspace.
Other major actions and initiatives include fostering adequate training
and education programs to support the nation‘s cybersecurity needs;
increasing the efficiency of existing federal cybersecurity training
programs; and promoting private-sector support for well-coordinated,
widely recognized professional cybersecurity certification.
4. Securing Government‘s Cyberspace--To help protect, improve, and
maintain government‘s cybersecurity, major actions and initiatives for
this priority include continuously assessing threats and
vulnerabilities to federal cyber systems; authenticating and
maintaining authorized users of federal cyber systems; securing federal
wireless local area networks; improving security in government
outsourcing and procurement; and encouraging state and local
governments to consider establishing information technology security
programs and participating in ISACs with similar governments.
5. National Security and International Cyberspace Security Cooperation-
-This priority identifies major actions and initiatives that can
strengthen U.S. national security and international cooperation. These
include strengthening cyber-related counterintelligence efforts;
improving capabilities for attack attribution and response; improving
coordination for responding to cyber attacks within the U.S. national
security community; working with industry and through international
organizations to facilitate dialogue and partnerships among
international public and private sectors focused on protecting
information infrastructures; and fostering the establishment of
national and international watch-and-warning networks to detect and
prevent cyber attacks as they emerge.
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 terrorist attacks, and it is based on eight guiding
principles. These include establishing responsibility and
accountability, encouraging and facilitating partnering among all
levels of government and between government and industry, and
encouraging market solutions wherever possible and government
intervention when needed. The strategy also establishes three strategic
objectives. The first is to identify and ensure the protection of the
most critical assets, systems, and functions in terms of national-level
public health and safety, governance, and economic and national
security and public confidence. This would include establishing a
uniform methodology for determining national-level criticality. The
second strategic objective is to ensure protection of infrastructures
and assets facing specific, imminent threats; and the third is to
pursue collaborative measures and initiatives to ensure the protection
of other potential targets that may become attractive over time. Under
this strategy, the Department of Homeland Security will provide overall
cross-sector coordination and will serve as the primary liaison and
facilitator for cooperation among federal agencies, state and local
governments, and the private sector. In addition, the Office of
Homeland Security will continue to act as the President‘s principal
policy adviser staff and coordinating body for major interagency policy
issues related to homeland security.
These recently released strategies identify priorities, actions, and
responsibilities for the federal government, including federal lead
departments and agencies and the Department of Homeland Security, as
well as for state and local governments and the private sector. The
strategies do not indicate time frames or milestones for their overall
implementation or for accomplishing specific actions or initiatives.
Effective Federal Information Security Programs Are Critical to CIP:
At the federal level, cyber CIP activities are perhaps the most
critical component of a federal department or agency‘s overall
information security program. Since September 1996, we have reported
that poor information security is a widespread federal government
problem with potentially devastating consequences.[Footnote 14]
Although agencies have taken steps to redesign and strengthen their
information system security programs, our analyses of information
security at major federal agencies have shown that federal systems were
not being adequately protected from computer-based threats, even though
these systems process, store, and transmit enormous amounts of
sensitive data and are indispensable to many federal agency operations.
For the past several years, we have analyzed audit results for 24 of
the largest federal agencies and found that all 24 had significant
information security weaknesses.[Footnote 15] Further, we have
identified information security as a governmentwide high-risk issue in
reports to the Congress since 1997--most recently in January
2001.[Footnote 16]
Our most recent analyses of audit reports published from October 2001
through October 2002 continue to show significant weaknesses in federal
computer systems that put critical operations and assets at
risk.[Footnote 17] Weaknesses continued to be reported in each of the
24 agencies included in our review, and they covered all six major
areas of general controls--the policies, procedures, and technical
controls that apply to all or a large segment of an entity‘s
information systems and help ensure their proper operation. These six
areas are (1) security program management, which provides the framework
for ensuring that risks are understood and that effective controls are
selected and properly implemented; (2) access controls, which ensure
that only authorized individuals can read, alter, or delete data; (3)
software development and change controls, which ensure that only
authorized software programs are implemented; (4) segregation of
duties, which reduces the risk that one individual can independently
perform inappropriate actions without detection; (5) operating systems
controls, which protect sensitive programs that support multiple
applications from tampering and misuse; and (6) service continuity,
which ensures that computer-dependent operations experience no
significant disruptions. Figure 3 illustrates the distribution of
weaknesses for the six general control areas across the 24 agencies.
Figure 3: Computer Security Weaknesses at 24 Major Federal Agencies:
[See PDF for image]
[End of figure]
The weaknesses identified place a broad array of federal operations and
assets at risk. For example,
* resources, such as federal payments and collections, could be lost or
stolen;
* computer resources could be used for unauthorized purposes or to
launch attacks on others;
* sensitive information, such as taxpayer data, social security
records, medical records, and proprietary business information, could
be inappropriately disclosed, browsed, or copied for purposes of
espionage or other types of crime;
* critical operations, such as those supporting national defense and
emergency services, could be disrupted;
* data could be modified or destroyed for purposes of fraud or
disruption; and:
* agency missions could be undermined by embarrassing incidents that
result in diminished confidence in their ability to conduct operations
and fulfill their fiduciary responsibilities.
Because the weaknesses we identified apply to controls for all or a
large segment of an agency‘s information systems, information security
may be no better for agencies‘ critical infrastructure assets. Further,
both we and the inspectors general have reported limited agency
progress in implementing PDD 63 requirements to protect critical
infrastructures from computer-based attacks. For example, as we
reported in September 2001, only limited efforts have been undertaken
to perform substantive, comprehensive analyses of infrastructure-
sector vulnerabilities and to develop related remedial plans.[Footnote
18] Also, a March 2001 report by the President‘s Council on Integrity
and Efficiency (PCIE) and the Executive Council on Integrity and
Efficiency (ECIE) identified significant deficiencies in federal
agencies‘ implementation of PDD 63 requirements to (1) establish plans
for protecting their own critical infrastructure that were to be
implemented within 2 years, or by December 2000, and (2) develop
procedures and conduct vulnerability assessments.[Footnote 19]
Specifically,
* many agency CIP plans were incomplete, and some agencies had not
developed such plans;
* most agencies had not completely identified their mission-essential
infrastructure assets; and:
* few agencies had completed vulnerability assessments of their minimum
essential infrastructure assets or developed remediation plans.
In addition, in March 2002 we testified on the efforts by the federal
government to implement requirements of the government information
security reform legislation (commonly referred to as GISRA),[Footnote
20] and reported that of the 24 large agencies we reviewed, 15 reported
that they had not implemented an effective methodology to identify
their critical assets.[Footnote 21]
Agencies Have Not Yet Completed Implementation of CIP Requirements:
The four agencies we reviewed (HHS, Energy, Commerce, and EPA) have
made progress for several requirements, such as preparing initial CIP
plans and appointing chief infrastructure assurance officers. However,
none has fully implemented the requirements of PDD 63 to protect its
critical cyber and physical infrastructure from attack. In particular,
the agencies are still focusing on the fundamental process of
identifying their critical assets and these assets‘ dependencies. Once
these assets and dependencies are identified, further steps will be
necessary, such as conducting or updating vulnerability assessments,
correcting identified vulnerabilities, and ensuring that these assets
are appropriately considered in continuity-of-operations planning.
Neither the agencies nor the administration has set milestones to
complete the asset and dependency identification process or estimated
resource requirements, and it could take years to complete these tasks
at the current pace.
Initial Progress Has Been Made in Implementing PDD 63 Management
Requirements:
The four agencies we reviewed have made progress in implementing
several PDD 63 requirements to manage their CIP efforts. Specifically,
they have all appointed chief infrastructure assurance officers,
developed initial CIP plans, and are establishing computer security
awareness and education programs and computer incident-response
capabilities to respond to cyber attack.
PDD 63 called for CIOs to be responsible for information assurance and
required the agencies to appoint chief infrastructure assurance
officers to be responsible for the protection of all other aspects of
their critical infrastructure. All four agencies have met this
requirement and appointed chief infrastructure assurance officers. The
designated chief infrastructure assurance officer is the Director of
Headquarters Security Operations within the Office of Security at
Energy and the Assistant Secretary for Budget, Technology and Finance
at HHS. At Commerce, the CIO is also designated as the chief
infrastructure assurance officer, as permitted by PDD 63. At EPA, there
are two designated officials or cochief infrastructure assurance
officers. According to an official with the Office of Solid Waste and
Emergency Response, the assistant administrator for this office was
appointed because of the office‘s responsibility for EPA‘s national
security efforts; and the assistant administrator for the Office of
Administration and Resources Management was also appointed because
approximately 90 percent of EPA‘s physical and cyber assets were housed
within that office.
PDD 63 also required every department and agency to develop a plan for
protecting its own critical infrastructure within 180 days of the
issuance of this directive, to implement those plans within 2 years of
the issuance of the directive, and to update those plans every 2 years.
As required, all four agencies prepared their initial CIP plans.
However, although HHS revised its initial plan in October 2000 to
incorporate review comments from a CIAO expert review team, none of the
agencies has formally updated its plan. HHS and Commerce both intend to
update their CIP plans, and in October 2002, HHS awarded a contract
that includes this task. However, according to Energy officials and a
March 2002 Energy IG report,[Footnote 22] Energy is deferring the
updating of its CIP plan until a national-level protection plan is
completed. Also, EPA officials indicated that they will defer updating
their plan pending further consultation with CIAO.
PDD 63 also required the establishment of a system for responding to a
significant infrastructure attack while it is under way, with the goal
of isolating and minimizing damage. Consistent with PDD 63‘s
cybersecurity emphasis and CIAO guidance highlighting the need to
establish a computer security-incident response capability,[Footnote
23] all four agencies responded that they are establishing incident
response capabilities and are reporting incidents to the General
Services Administration‘s (GSA) Federal Computer Incident Response
Center.[Footnote 24] Further, HHS‘s CIO reported that, during fiscal
year 2002, the department commissioned an incident response and
notification study by a security contractor and will use the results to
formulate the next stage of its enterprise security program. Recent IG
evaluations required by GISRA confirm most of these agencies‘ actions
to improve incident-handling capabilities. In particular, Commerce‘s IG
reported that a computer incident-response team was established in
fiscal year 2002 to provide this capability for operating units that
did not have their own, thus ensuring coverage departmentwide. In
addition, the EPA IG reported that EPA plans to outsource its incident-
handling function.
Another PDD 63 requirement calls for a vulnerability awareness and
education program to be established within the government to sensitize
people regarding the importance of security and to train them in
security standards, particularly regarding cybersystems. Overall,
agency efforts related to this requirement primarily focus on
information security education and awareness, and all four agencies
indicate that they are providing their staff with such training, some
of which includes the use of Web-based or automated training tools.
However, although IGs‘ recent GISRA evaluations confirm these efforts,
they also reported common weaknesses for these agencies, including that
these training programs had not ensured that employees with significant
information security responsibilities were receiving adequate
training.
Table 2 summarizes the results of the agencies‘ implementation efforts
related to requirements for managing PDD 63 efforts.
Table 2: Results of Agencies‘ Implementation of Selected PDD 63
Requirements:
[See PDF for image]
[End of table]
Critical Asset Identification Is Still Not Complete:
The four agencies we reviewed all provide information and physical
security to protect agency assets and reported that they have taken
additional protective actions since the terrorist attacks of September
11, 2001, such as increasing guards and building security, performing
vulnerability assessments for agency facilities, and updating plans to
ensure the continuity of essential operations. However, over 4 years
after PDD 63 was issued, the agencies have not completed the
fundamental processes of identifying their critical assets and their
dependencies on other public-and private-sector assets. Although all
four agencies prepared their required initial CIP plans, these plans
focused on protecting hundreds of assets considered essential to the
agencies‘ missions rather than focusing on those assets that are
critical to the nation.
In October 1998, a month before agencies‘ initial CIP plans were due,
CIAO issued its Vulnerability Assessment Framework.[Footnote 25] The
framework was intended to provide detailed guidance to federal agencies
on how to identify their critical infrastructures, identify
interdependencies and vulnerabilities of those infrastructures, and
provide the basis for developing remediation plans. However, CIAO
officials concluded, on the basis of a review of agency CIP plans and
subsequent discussions with agency officials, that agencies did not
find the framework particularly helpful in carrying out agency planning
efforts. Further, several agencies were unclear whether ’critical“
organizations, personnel, systems, and facilities to be identified
using the framework referred only to those specific missions performed
by the individual departments and agencies or more broadly to the
performance of functions and missions by federal agencies on behalf of
the nation.[Footnote 26]
On the basis of this review of the agencies‘ initial plans, CIAO
decided that the management of CIP programs required a new functional
approach to defining and identifying critical assets and their
dependencies, and it shifted the focus to identifying assets and
dependencies that, under PDD 63, are deemed critical to the federal
government‘s carrying out its responsibilities for national security,
maintaining the orderly functioning of the national economy, and
ensuring the health and safety of Americans. To accomplish this goal
and provide the agencies with additional guidance, in March 2000, CIAO
began offering its Project Matrix methodology. Project Matrix consisted
of a three-step process in which each civilian federal agency
identifies (1) its critical assets; (2) other federal government
assets, systems, and networks upon which its critical assets depend to
operate; and (3) all associated dependencies on private-sector owned
and operated critical infrastructures. The Project Matrix methodology
defines ’critical“ as the responsibilities, assets, nodes, and networks
that, if incapacitated or destroyed, would jeopardize the nation‘s
survival; have a serious, deleterious effect on the nation at large;
adversely affect large portions of the American populace; and require
near-term, if not immediate, remediation (currently defined as within
72 hours). It defines ’assets“ as tangible equipment, applications, and
facilities that are owned, operated, or relied upon by the agency, such
as information technology systems or networks, buildings, vehicles
(aircraft, ships, or land), satellites, or even a team of people.
Once critical assets and their associated dependencies are identified,
the agencies are to assess their vulnerability to physical or cyber
attack and, if vulnerabilities are found, to develop and implement
plans to manage the risks posed by potential attacks to the performance
of essential functions and services. Such plans are to seek to deter
attacks from happening in the first place, protect critical assets from
damage or destruction if attacks occur, mitigate the operational impact
of attacks if protective measures fail, restore operations if attacks
disrupt services, and reconstitute any assets damaged or destroyed
during attacks.
To perform Project Matrix step 1, a CIAO team is to work with the
participating agency to identify its PDD 63-relevant assets--that is,
pieces of equipment, facilities, or people that are owned, operated, or
relied upon by the agency to fulfill its most critical
responsibilities. Typically this process includes the team‘s conducting
document reviews and interviews with selected program managers, to
understand how the agency is organized and functions; developing a
universal list of physical and cyber assets resident in the agency;
producing a revised list of candidate assets by eliminating those not
critical to the support of PDD 63 national requirements; and training
agency program managers in how to complete an ’infrastructure asset
evaluation“ response for each candidate-list asset. This infrastructure
asset evaluation requires the agency to provide answers to a series of
questions that describe the asset and its role in supporting the
objectives of national or regional security, economic stability, and
public health and safety. These responses are then scored by CIAO and,
subject to further deliberations by the agency, those with scores that
exceed a certain threshold are identified as the agency‘s critical
assets. Generally, this approach identifies a limited number of
critical assets, thus enabling the agency to focus its CIP efforts on
those that are most essential to the nation.
All four of the agencies were in some stage of performing Project
Matrix step 1 at the time of our review. HHS originally completed
step 1 in December 2000 but is now revisiting that analysis given the
terrorist attacks that began on September 11, 2001. For Energy and EPA,
CIAO had prepared draft reports for step 1 (dated August 2001 and May
2002, respectively) that presented a compilation of the evaluation
responses and resultant analyses and tentatively identified their
critical assets. Both agencies are continuing to review and update
information in these draft reports. Finally, although Commerce‘s 1998-
1999 efforts to identify its critical infrastructure assets were the
basis upon which Project Matrix step 1 was built, Commerce has now
begun to formally perform the step 1 process to refine its list of
critical assets.
The agencies we reviewed are all performing the step 1 process and,
until they have completed it, their critical assets are only
tentatively identified. This is true even for HHS, which recognizes
that what is identified as a critical asset may change with different
national needs and circumstances, and is revisiting the step 1 process
it completed over 2 years ago. Table 3 shows how this process winnows
down the total number of agency assets to a handful. The critical
assets the agencies tentatively identified include both cyber and
physical, and they range from computer centers, laboratories, and
buildings to mobile laboratories and teams of experts. However, because
of their sensitivity both individually and collectively, we do not
specifically identify any of these in this report.
Table 3: Tentative Results of Agencies‘ Efforts to Identify Their
Critical Assets:
Agency: HHS; Universe: 900; Number of candidates: 97; Number of
critical assets: 18.
Agency: Energy; Universe: 2,500; Number of candidates: 88; Number of
critical assets: 14.
Agency: EPA; Universe: 350; Number of candidates: 27; Number of
critical assets: 18.
Agency: Commerce; Universe: 231; Number of candidates: 42; Number of
critical assets: 10[A].
Source: Department of Health and Human Services, Department of Energy,
Environmental Protection Agency, Department of Commerce (data); GAO
(analysis).
[A] Estimated by Commerce officials based on ongoing Project Matrix
step 1 efforts.
[End of table]
In Project Matrix step 2, an agency is to identify the other federal
government assets, systems, and networks upon which its critical assets
depend to operate. Currently, CIAO plans to assist an agency in
analyzing two of its critical assets, and the agency is to perform the
analyses for the remaining assets. Two of the four agencies we reviewed
had not initiated the next steps of the Project Matrix methodology.
Specifically, although Commerce was a pilot for step 2 in 1999, of the
four agencies, only HHS and Energy have begun this step, with CIAO
assistance, for a few critical assets. In addition, HHS officials
report that the department has awarded a contract to complete step 2
for all of its critical assets.
Further, none of the agencies had begun step 3, in which an agency
identifies and analyzes the critical assets‘ dependencies on nonfederal
infrastructures and identifies potential points of failure. Identifying
such interdependencies and dependencies is a critical step. For
example, Energy officials noted that the Bureau of Reclamation within
the Department of the Interior, the Army Corps of Engineers within DOD,
and the Tennessee Valley Authority all operate dams that supply
electricity to some of Energy‘s critical assets and that could affect
the availability of these assets. This dependency is also an important
consideration for these other agencies‘ CIP efforts, particularly if
these agencies have not yet identified such dependencies. For this
example, according to CIAO officials, none of these other agencies has
undergone a Project Matrix review.
Although the agencies we reviewed are all participating in Project
Matrix, it is difficult to estimate when they will complete the
process. None of the agencies had estimates of when the individual
steps or overall process would be completed or of the total resources
that would be required, and CIAO officials emphasized that the actual
time to complete a Project Matrix step depends on an agency‘s
priorities and resources.
As an indication of the time required to complete Project Matrix, CIAO
officials told us that to assist an agency, CIAO itself requires a
total of approximately 1,000 staff hours to complete step 1 and 750
staff hours per asset to complete step 2 (CIAO plans to assist the
agencies in analyzing only two of their critical assets for this step).
Since no agency has completed step 3, these officials projected that
CIAO would also require 250 staff hours per asset for this step. As an
indication of the time required to complete Project Matrix from the
agency perspective, an HHS official stated that it took 6 to 7 months
to complete a step 2 analysis for one of the department‘s critical
assets. Further, Energy officials estimated that it will take 700 hours
of staff time and $100,000 in contract support costs to do step 2 for
one critical asset, and they now question whether they will have the
funding to complete step 2. On the basis of these estimates, it could
take years for these agencies to complete their analyses for all
critical assets at their current pace.
In addition to there being no agency Project Matrix completion
estimates, there currently is no governmentwide milestone that would
indicate when the agencies should complete their analyses other than
those in PDD 63 that called for an initial operating capability by the
close of 2000 to protect the nation‘s critical infrastructures from
intentional destructive acts, and for an enhanced capability no later
than May 2003. In September 2001, we recommended that the federal
government‘s strategy define interim objectives and milestones for
achieving CIP goals and a specific action plan for achieving these
objectives.[Footnote 27] However, subsequent federal CIP policy and
strategy do not contain any specific milestones that would require
agencies to complete implementation of requirements. Specifically for
Project Matrix, in February 2002 OMB reported to the Congress that it
was requiring all large federal agencies to undergo a Project Matrix
review[Footnote 28] and, according to a CIAO official, has set a goal
of having 31 agencies complete Project Matrix. However, OMB did not
establish a deadline for these reviews to be completed. As of July
2002, CIAO reported that of the 31agencies targeted, 18 had begun their
reviews, and of those, only 5 are shown as completing step 1 (including
HHS, for its December 2000 results) and only 5 had begun step 2
(includes HHS and Energy).[Footnote 29] CIAO‘s deputy director said
that this office‘s current goal is to complete Project Matrix reviews
for 24 of the 31 identified agencies by the end of fiscal year 2004 and
for the remaining 7 in fiscal year 2005. However, this goal is internal
to CIAO and has not been communicated to the agencies.
Finally, the CIAO deputy director told us that at the request of the
Office of Homeland Security, CIAO is currently revising and
streamlining its Project Matrix methodology to approach step 1 from a
high-level functional basis that would be less labor intensive for the
agencies instead of from the level of the individual asset owners. In
addition, the revision would combine the identification of these
assets‘ dependencies on other government and private-sector assets
(formerly steps 2 and 3) as step 2. This official estimated that under
the new streamlined methodology, step 1 would take an agency from 8 to
12 weeks to complete, depending on its size. He could not, however,
estimate whether the new combined step 2 would require less time or
resources for CIAO or the agencies.
Agencies‘ Efforts to Implement PDD 63 Requirements for Critical Assets
Are Also Incomplete:
Several PDD 63 requirements related to the agencies‘ protection of
their own critical infrastructures are dependent on agencies‘
identification of critical assets, including conducting and
periodically updating vulnerability assessments, developing a
recommended remedial plan based on vulnerability assessments, and
rapidly reconstituting minimum required capabilities for successful
infrastructure attacks. Data collected by the agencies for Project
Matrix show that agencies‘ efforts to implement these requirements for
all critical assets are incomplete and do not ensure that critical
asset vulnerabilities are identified and corrected, and that these
assets are appropriately considered in planning for the continuation of
critical operations.
PDD 63 requires agencies to conduct vulnerability assessments for their
critical assets, and federal vulnerability assessment guidance requires
that these vulnerability assessments be periodically updated. The four
agencies we reviewed and CIAO identified several sources of guidance
for conducting vulnerability assessments for cyber assets, including
CIAO‘s October 1998 Vulnerability Assessment Framework, its January
2000 Practices for Securing Critical Information Assets, and NIST‘s
October 2001 Risk Management Guide for Information Technology
Systems.[Footnote 30] As defined in CIAO‘s January 2000 guidance, a
cyber vulnerability assessment is an examination of the ability of a
system or application (including current security procedures and
controls) to withstand assault, and this examination may be used to
(1) identify weaknesses that could be exploited and (2) predict the
effectiveness of additional security measures in protecting information
resources from attack. With regard to assessing the vulnerability of
physical facilities, all four agencies indicated that they used a 1995
study by the U.S. Marshals Service, which provides recommended minimum
security standards for five different building security
levels.[Footnote 31] These levels are based primarily on staffing size,
number of employees, use, and the need for public access, but the
determination of the security level for a facility also considers
threat intelligence, crime statistics, and agency mission. Neither PDD
63 nor the above guidance specifies an interval for how often these
assessments should be updated, but the guidance does indicate that
updates should be performed when significant changes occur. However,
guidance by GSA‘s Federal Protective Service does call for periodic
vulnerability surveys for facilities according to their security
levels, with frequencies ranging from every 4 years for level 1 and 2
facilities to every 2 years for more sensitive level 4 facilities.
For the three agencies we reviewed that had tentatively identified
their critical assets (Energy, EPA, and HHS), data collected by the
agencies in performing Project Matrix step 1 showed that their
vulnerability assessment efforts are incomplete.[Footnote 32] As
indicated by the agencies, the critical assets are characterized as
cyber only, physical only, or both cyber and physical. As a result,
some assets required either a cyber or physical vulnerability
assessment, and others required both. Table 4 summarizes these
vulnerability assessment data for these three agencies, through
December 2002. First, it shows that none of the agencies had completed
cyber or physical vulnerability assessments for all of its assets. For
example, of HHS‘s 15 critical assets with cyber characteristics, 10 (or
67 percent) had cyber vulnerability assessments. Table 4 also shows
that for the vulnerability assessments that were performed, HHS and
Energy had a number of both cyber and physical vulnerability
assessments that were 2 years old or older. These older assessments
predate the September 11th attacks, which experts agree represent a
significant change in threat and attack scenarios. In addition, for
Energy, these older vulnerability assessments were conducted before the
assets were tentatively identified as critical.
Table 4: Status of Agency Vulnerability Assessments, as of December
2002:
[See PDF for image]
[End of table]
In addition to not conducting or updating vulnerability assessments,
our analyses of assessments for selected critical assets showed that
some physical assessments were not prepared specifically for those
assets. Rather, the physical vulnerability assessments we analyzed at
HHS, EPA, and Energy sometimes pertained to overall facilities or
buildings, and it was not clear to what extent physical vulnerabilities
were assessed for a specific critical asset housed within those
facilities or buildings. EPA officials reported that because EPA used
the U.S. Marshals Service study as the standard for assessing the
facilities or buildings that house most of its critical assets, they
believe that the physical infrastructure vulnerabilities associated
with these critical assets were properly assessed. We agree that these
vulnerability assessments did indicate the facility levels assigned
according to criteria in the U.S. Marshals Service study. However,
these assessments still did not indicate that critical assets housed in
a facility or building were explicitly considered either in determining
the facility levels or in assessing the threats, vulnerabilities, or
risk levels for these facilities. As a result, based on the reported
assessment results, we were unable to determine whether physical
infrastructure vulnerabilities associated with critical assets had been
properly assessed.
All four agencies, including Commerce, are continuing their
vulnerability assessment efforts, but it was difficult to estimate when
these efforts would provide current assessments for all assets. For
example, both EPA and Energy identified teams of people as critical
assets and indicated that they needed additional guidance to conduct
vulnerability assessments for these assets. Further, the agencies
generally had no system or organization that routinely monitored the
status of both cyber and physical vulnerability assessments for their
critical assets. Instead, they usually relied on obtaining these data
from the asset owners on an ad hoc basis. This practice sometimes
resulted in conflicting data between different agency organizations.
For example, officials in the HHS Office of Information Resources
Management and its Office of Real Property and Management provided
conflicting dates for when some physical vulnerability assessments had
been completed, which they reconciled at our request.
All four agencies stated that they prepared remedial plans on the basis
of individual vulnerability assessments, as required by PDD 63, and
that the organization responsible for the asset was responsible for
ensuring that identified vulnerabilities are managed. In addition, for
cyber-related vulnerabilities, CIO officials from the four agencies all
stated that identified information security weaknesses are reported and
monitored as part of their tracking of information security corrective
actions for GISRA. Recent GISRA independent evaluations conducted by
these agencies‘ IGs generally confirmed that the agencies do have
processes for tracking their information security weaknesses. Further,
some agencies are reporting overall progress in correcting identified
information security weaknesses. For example, although neither their
IGs nor we have validated corrective actions, both Commerce and EPA
officials report that they have corrected most information security
weaknesses identified in our latest audit reports on their computer
operations.[Footnote 33] However, despite this potential progress for
cyber vulnerabilities, agency officials acknowledge that they do not
have a comparable process to track corrective actions for
vulnerabilities identified through physical vulnerability assessments,
nor do they ensure that all cyber and physical vulnerabilities and
corrective actions are monitored specifically for their critical
assets.
In addition to assessing and correcting their vulnerabilities, PDD 63
requires the rapid reconstitution of agencies‘ minimum required
capabilities--that is, their critical assets. However, data reported by
the agencies showed that only one of the three agencies with tentative
critical assets (EPA) had included all these assets in its continuity-
of-operations plans--plans that provide for the continued performance
of essential federal functions (see table 5 below).[Footnote 34] Part
of the data collected by the agencies for Project Matrix step 1
concerns whether an asset is included in a continuity-of-operations
plan, to determine whether it will be restored as one of the agency‘s
essential functions. CIAO officials stated that addressing critical
assets in such plans is sufficient to meet the requirement for rapidly
reconstituting minimum required capabilities, as long as these plans
require reconstitution of the critical asset within 72 hours of its
disruption. Although Project Matrix data do not indicate whether the
plans meet the 72-hour criterion for a critical asset, they do show
that for the three agencies with tentative critical assets, only 29 (58
percent) of the 50 assets identified were included in continuity-of-
operations plans. Project Matrix data also showed that of those 29
included in the plans, 13 (45 percent) were over 2 years old. Although
federal continuity-of-operations guidance does not specify how often
plans should be updated, plans over 2 years old predate the terrorist
attacks that occurred on September 11, 2001, and for Energy and EPA,
predate the identification of their tentative critical assets. At least
one agency, HHS, indicated that it is in the process of revising its
continuity-of-operations plan, and it will ensure that all critical
assets are included in its 72-hour recovery plan.
Table 5: Critical Assets Included in Agencies‘ Continuity-of-
Operations/Continuity-of-Government Plans as of December 2002:
[See PDF for image]
[End of table]
ISACs‘ Progress in Implementing PDD 63-Suggested Activities Is Mixed:
In addition to specific requirements for federal agencies, PDD 63
encouraged the voluntary creation of ISACs and suggested other
activities for them to undertake in order to effectively gather,
analyze, and disseminate information to and from infrastructure sectors
and the federal government. The five ISACs we reviewed have the same
basic operations, but all have different characteristics. For example,
these voluntary ISACs were established at different times, and they had
different funding sources and operational methods. In addition, their
progress varies in terms of industry participation levels and the
extent to which they have undertaken activities suggested by PDD 63.
Establishment and Operation of ISACs Differs:
PDD 63 suggested that ISACs could serve as the mechanism for
(1) gathering, analyzing, and appropriately sanitizing and
disseminating private-sector information to both industry and NIPC and
(2) gathering and analyzing information from NIPC for further
distribution to the private sector. Further, the directive encouraged
the voluntary creation of ISACs and left their actual design and
functions, along with their relationship with NIPC, to be determined by
the private sector in consultation with the federal government. As a
result, the five ISACs we reviewed were established differently and
with membership open to a wide variety of organizations, according to
the specific industry sector. The following brief overview of each ISAC
illustrates their variations:
* The Information Technology ISAC is managed as a limited liability
corporation; membership is open to companies that are engaged in the
information technology industry or that use the Internet for a major
part of their business. Members can include vendors, manufacturers, or
providers of Internet and E-commerce products (both hardware and
software) and information technology solutions and services.
* The Telecommunications Infrastructure ISAC was established not as a
separate entity but as a function of the National Coordinating Center
for Telecommunications--a government-industry operational and
collaborative body housed within the National Communications System.
The National Communications System is being transferred to the new
Department of Homeland Security, which is now the designated sector
liaison. Membership 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.
* The Energy ISAC was originally managed as a limited liability
corporation, but in late 2002 it changed its corporate structure to a
tax-exempt organization. Its member companies are primarily in the oil
and natural gas industries, and their activities include the
exploration, production, processing, transmission, distribution,
transportation, storage, trading, supervisory control and data
acquisition, and
E-commerce of energy commodities.
* The Electricity ISAC is managed and operated by the North American
Electric Reliability Council, a nonprofit corporation that promotes
electric system reliability and security. Its 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.
* For the water sector, the Association of Metropolitan Water Agencies,
a nonprofit corporation, is currently serving as the interim ISAC.
Membership is open to drinking water and wastewater utilities,
regardless of size.
The basic purpose of these ISACs‘ operations is the same: to facilitate
information sharing among members by collecting, analyzing, and
disseminating information on vulnerabilities, threats, intrusions, and
anomalies reported by members, the government, and other sources, in
order to avert or mitigate the impact of these factors. Also, all five
reported that they provide some level of watch services 24 hours a day,
7 days a week.
Despite the overall similarities, these organizations differ in several
ways. For example, existing organizations performed functions for some
sectors many years before being designated as ISACs. The National
Coordinating Center for Telecommunications performed some operations
for the telecommunications sector beginning in 1984, and was designated
an ISAC in January 2000. Similarly, before being designated for the
electricity sector in October 2000, the North American Electric
Reliability Council had been performing similar operations since 1968.
In contrast, the Information Technology ISAC initiated operations in
December 2000 in direct response to PDD 63. Further, although ISACs for
Energy and Water were under consideration in response to PDD 63, they
did not initiate operations until after September 11, 2001.
Industry participation reported by the ISACs--important to ensuring
that incident and threat information is gathered and disseminated
sectorwide--also varies. All the ISACs reviewed reported that they
represent a majority of their respective industries, with highest
representation reported by Information Technology (85 to 90 percent of
the assets of Internet equipment and security providers by market
share) and Telecommunications (over 90 percent of wire line
telecommunications service providers by revenue market share, as well
as a significant representation of wireless or Internet service and
Internet backbone providers). The Energy ISAC reported that it
represents 60 to 70 percent of the assets of the oil and gas industry,
and the Electricity ISAC reported that it represents approximately 80
percent of the sector, including large and small utilities, regional
utilities, and power marketers. The Water ISAC reported that it
represents utilities that are serving 80 percent of drinking water and
wastewater customers.
Table 6 summarizes basic information on each of the five ISACs
reviewed, including when they began operations and their
representation.
Table 6: Overview of Selected Information Sharing and Analysis Centers:
ISAC: Telecommunications; Lead agency: Department of Commerce, through
the National Communications System[ A]; Date operations began: Some
operations since 1984; Representation: 90% of wire line
telecommunications service providers by revenue market share, and
significant representation of wireless or Internet service and Internet
backbone providers.
ISAC: Electricity; Lead agency: Department of Energy; Date operations
began: Some operations since 1968; Representation: Approximately 80% of
sector, including large and small utilities and power marketers.
ISAC: Information Technology; Lead agency: Department of Commerce,
through its National Telecommunications and Information
Administration[ A]; Date operations began: December 2000;
Representation: 85-90% of assets of Internet equipment and security
providers by market share.
ISAC: Energy; Lead agency: Department of Energy; Date operations began:
November 2001; Representation: 60-70% of sector.
ISAC: Water; Lead agency: Environmental Protection Agency; Date
operations began: October 2001; Representation: Utilities that are
serving 80% of drinking water and wastewater customers.
Source: ISACs.
[A] The new Department of Homeland Security is now the designated lead
agency for this sector.
[End of table]
The methods used to fund start-up and operational costs also differ by
ISAC. For example, start-up and operational funding for
Telecommunications and Electricity are provided through their
sponsoring organizations, the National Communications System and the
North American Electric Reliability Council, respectively. On the other
hand, individual sector companies donated start-up funding for the
Information Technology ISACs, and operational funding comes from
membership fees paid by members. For the Energy ISAC, industry
associations provided start-up funding, and membership fees initially
provided operational funding. However, this ISAC reported that in the
fall of 2002, the Office of Energy Assurance in the Energy Department
agreed to fund ISAC operations--an agreement sought so that membership
costs would not prevent smaller companies from joining. The new, cost-
free Energy ISAC began operations and broad industry solicitation for
membership in February 2003. For Water, a private-sector association
provided start-up and initial operational funding, and the EPA also
provided a grant for system development and expanded operations.
The ISACs reported differences in their management and operations.
Although Telecommunications and Electricity were both developed as part
of preexisting sector activities, Telecommunications is housed in the
National Communications System (a government entity), with private
contractors performing operations co-located and procedurally
integrated with government operations staff and industry
representatives, and Electricity is part of the private-sector North
American Electric Reliability Council, with its operations performed
in-house. The Information Technology ISAC is a limited iability
corporation, created specifically to oversee its operations, which are
performed by a private contractor. Originally created as a limited
liability corporation, the Energy ISAC reported that it changed its
corporate structure to a tax-exempt organization to better facilitate
and manage the funds provided by the Energy Department. And finally,
the private-sector Association of Metropolitan Water Agencies initially
performed operations in-house for Water. However, according to an ISAC
official, in January 2003 a contractor began to perform operations, and
subscribers are currently being actively recruited. Table 7 summarizes
the entities that manage and operate each of the ISACs.
Table 7: Entities that Manage and Operate Selected Information Sharing
and Analysis Centers:
ISAC: Telecommunications; Management entity: National Communications
System; Operational entity: Contracted watch and analysis operation co-
located and integrated with government operational staff and industry.
ISAC: Electricity; Management entity: North American Electric
Reliability Council; Operational entity: Operated in-house by the North
American Electric Reliability Council.
ISAC: Information Technology; Management entity: Limited liability
corporation; Operational entity: Contracted out to Internet Security
Systems.
ISAC: Energy; Management entity: Tax-exempt organization; Operational
entity: Contracted out to Predictive Systems, Inc..
ISAC: Water; Management entity: Association of Metropolitan Water
Agencies; Operational entity: Initially operated in-house, but
contractor operations began in January 2003.
Source: ISACs.
[End of table]
Progress for Suggested ISAC Activities Is Mixed:
PDD 63 suggested several key ISAC activities to effectively gather,
analyze, and disseminate information--activities that could improve the
security posture of the individual sectors, as well as provide an
improved level of communication within and across sectors and all
levels of government. These are as follows:
* Establishing baseline statistics and patterns on the various
infrastructures. This includes developing a database on the normal
levels of computer security incidents that would be used for analysis
purposes, to provide early indications of cyber attacks.
* Serving as a clearinghouse for information within and among the
various sectors. This includes disseminating information technology
security information received from NIPC and members--such as incident
reports and warnings, as well as ways to prevent or recover from them-
-to other ISACs.
* Providing a library of historical data for use by the private sector
and government. This includes collecting and posting information such
as incident reports and warnings, references, vulnerability
assessments, and related documents that can be accessed by all industry
and government partners with a ’need to know“ for CIP.
* Reporting private-sector incidents to NIPC. This includes reporting
to NIPC security incidents that members authorize for reporting, and
using standard operating procedures that contain guidelines on the
event types and thresholds to report.
The ISACs showed mixed progress in implementing these activities, and
none had completed all of them. By not fully implementing all these key
activities, the ability of the ISACs to gather, analyze, and
disseminate information within and across sectors and the government
could be limited. Specifically, four of the five reported that efforts
to establish baseline statistics were still in progress. Also, although
three of the five reported that they serve as the clearinghouse for
their own sector and also coordinate with other sectors, the remaining
two reported that they serve as the clearinghouse for their own sector
but are not coordinating with other sectors. Only one ISAC reported
that it provides a library of incidents and historical data that is
available to both the private sector and the federal government. Three
reported that although they maintain such a library, it is available
only to the private sector because of concerns that, if made available
to the government, the information could be released under the Freedom
of Information Act (FOIA).[Footnote 35] The remaining ISAC reported
that it has yet to develop a library, but plans to do so. Finally,
officials for the Telecommunications, Information Technology,
Electricity, and Water ISACs stated that they report incidents to NIPC
on a regular basis and estimated that they report one to four incidents
per month. According to NIPC officials, this volume of reporting may be
appropriate for these particular ISACs, given established reporting
thresholds, and other sources do not indicate that incidents are going
unreported. In addition to formal incident reporting, the Information
Technology ISAC reports that it and several other ISACs conduct daily
information exchanges with the NIPC on current vulnerabilities,
viruses, and attacks that affect cyber security. In contrast, officials
for the Energy ISAC said that they have not reported to the government
because of FOIA and antitrust concerns. Table 8 summarizes the reported
status of the five ISACs in performing the activities suggested by PDD
63.
Table 8: ISACs‘ Progress in Performing Activities Suggested by PDD 63:
Activity: Establish baseline statistics; ISAC: Telecommunications: In
progress; ISAC: Electricity: In progress; ISAC: Information Technology:
Yes; ISAC: Energy: In progress; ISAC: Water: In progress.
Activity: Serve as clearinghouse within and among sectors; ISAC:
Telecommunications: Yes; ISAC: Electricity: Yes; ISAC: Information
Technology: Yes; ISAC: Energy: Only within own sector; ISAC: Water:
Only within own sector.
Activity: Provide library to private sector and government; ISAC:
Telecommunications: In progress; ISAC: Electricity: Yes; ISAC:
Information Technology: Available only to private sector; ISAC: Energy:
Available only to private sector; ISAC: Water: Available only to
private sector.
Activity: Report incidents to NIPC; ISAC: Telecommunications: Yes;
ISAC: Electricity: Yes; ISAC: Information Technology: Yes; ISAC:
Energy: No; ISAC: Water: Yes.
Source: ISACs.
[End of table]
Efforts to Improve Cooperation and Interaction with ISACs and
Assistance to Agencies Continue:
NIPC continues to provide a number of information products to share
warning information and to take actions to improve cooperation and
interaction with the ISACs. Federal lead agencies have also assisted in
ISAC establishment and operation. Citing some early problems in
assistance and cooperation that have largely been overcome, ISACs
identified areas in which efforts could be improved, such as receiving
additional and more timely warnings. CIAO continues to assist federal
agencies in using the Project Matrix methodology to identify critical
assets and their dependencies.
NIPC and Agency Efforts to Improve Cooperation and Interaction with
ISACs:
As part of its overall responsibility to serve as a national critical
infrastructure threat assessment, warning, vulnerability, and law
enforcement investigation and response entity, PDD 63 requires NIPC to
provide a national focal point for gathering and disseminating
information on threats to critical infrastructures, to establish its
own relations with the ISACs, to provide them with sanitized or
unsanitized reports, and to issue warning products in response to
increases in threat condition. In addition, the lead agencies that PDD
63 designated for each critical infrastructure sector were also
required to work with sector representatives in addressing problems
related to CIP, including the creation of a private-sector ISAC.
To meet PDD 63 requirements to provide a national focal point and to
disseminate threat and warning information, NIPC issues a variety of
information products with three levels of infrastructure warnings--
assessments, advisories, and alerts--that are developed and distributed
as consistent with the FBI‘s National Threat Warning System.
Assessments address broad, general incident or issue awareness
information and analysis that are significant and current, but they do
not necessarily suggest immediate action. Advisories address
significant threat or incident information that suggests a change in
readiness posture, protective options, or response. Alerts address
major threat or incident information addressing imminent or in-progress
attacks targeting specific national networks or critical
infrastructures. These warning products have concentrated on cyber
threats to critical infrastructures. And although these warnings will
often be based on classified material and will include dissemination
restrictions, NIPC usually publishes them in an unclassified format
that reaches national security and civilian government agency
officials, as well as infrastructure owners.
Over the past year, the NIPC has developed two additional types of
warning products that address physical threats to critical
infrastructures. Information Bulletins communicate issues that pertain
to all or many of the critical infrastructures and are disseminated for
informational purposes only. These bulletins are sent directly to the
ISACs, as well as posted on NIPC‘s public Web site. Sector
Notifications communicate sensitive and developing information
relating to one or more of the nation‘s critical infrastructures. The
notifications are sent to the ISACs for those infrastructures and are
not publicly posted.
In his July 2002 congressional testimony, the NIPC director stated that
since inception, NIPC has issued over 120 warning products, and that a
number of these have preceded incidents or prevented them entirely by
alerting the user community to a new vulnerability or hacker exploit
before acts are committed or exploits are used on a widespread basis.
In addition, information on NIPC‘s Web site shows that it has issued 2
threat assessments, 11 advisories, and 3 alerts for calendar year 2002.
These warnings concerned threats ranging from computer viruses and
worms to a warning of potential cyber protests and potential system
vulnerabilities, such as within the Simple Network Management Protocol
(a protocol used by routers, switches, and hubs on the Internet and
other related equipment). In addition, the NIPC has issued 11
Information Bulletins and 5 Sector Notifications during this period.
Other NIPC information products apprise policymakers and decisionmakers
of current events, incidents, developments, and trends related to CIP.
These products include its biweekly CyberNotes, which provides security
and information system professionals with information on cyber
vulnerabilities, hackers, viruses, and other critical infrastructure-
related best practices, and, until recently, its monthly Highlights. In
addition, in November 2002, NIPC also issued a white paper, Risk
Management: An Essential Guide to Protecting Critical Assets, to assist
security specialists and asset stakeholders in assessing physical and
cyber risks to their organizations‘ critical assets.
In addition to information products, the FBI and NIPC lead and
facilitate the InfraGard Program--an information-sharing and analysis
effort that provides a mechanism for the public and private sectors to
exchange information pertaining to cyber intrusion matters, computer
network vulnerabilities, and physical threats on infrastructures. Under
this program, private-sector members and FBI field representatives form
local area chapters. InfraGard members, who currently total over 6,700,
include state and local law enforcement agencies, other government
entities, private industry, and academia. Actions to facilitate this
program include gathering information and distributing it to members,
educating the public and members on infrastructure protection, and
disseminating information through the InfraGard network.
In discussing NIPC‘s sharing of warning information with the ISACs, two
ISACs suggested that NIPC provide more warnings and alerts and two
suggested that it provide more timely warnings. One also suggested that
NIPC issue more detailed warnings that provide additional bases for
action. The Information Technology ISAC suggested that NIPC further
streamline the number of cyber threat warning levels, which can be
confusing to industry. Further, it stated that NIPC‘s alerts represent
the sum total input from ISACs and other sources and, thus, often
repeat ISAC information, usually in a less timely manner than did the
original reports. This ISAC suggested that in addition to defining the
government‘s specific information requirements, NIPC could add real
value by publishing timely aggregate reports that include analyses not
available elsewhere.
NIPC officials said that they are working to address some of these
issues and reported that efforts are under way to educate the ISACs and
the industries on the importance of submitting incident information,
which could result in additional warnings. These officials also stated
that their review procedures for issuing physical threat warnings are
being streamlined and that they expect both the process and the
timeliness to improve. In addition, these officials acknowledged that
some threat alerts are at a general level and do not indicate what
action should be taken, but they added that NIPC began issuing more
high-level alerts in direct response to industry requests for high-
level information that might indicate future attacks, such as those
experienced on September 11th.
Regarding the requirement to establish its own relationship with the
ISACs, in April 2001, we reported that NIPC and other government
entities had not developed fully productive information-sharing
relationships, but that NIPC had undertaken a range of initiatives to
foster information-sharing relationships with ISACs, as well as with
government and international entities.[Footnote 36] We recommended that
it formalize these relationships and develop a plan to foster a two-way
exchange of information between NIPC and the ISACs. In response to our
recommendations, NIPC officials stated that in the summer of 2001 a new
ISAC development and support unit had been created whose mission is to
enhance private-sector cooperation and trust, resulting in a two-way
sharing of information. Currently, 12 ISACs in total have been formed,
and NIPC officials reported that the center has signed information-
sharing agreements with most of these, including all but one of those
we reviewed: the Energy ISAC. These officials added that most of the
agreements contained industry-specific thresholds for cyber and
physical incident reporting. Consistent with those sharing agreements,
a number of ISACs currently transmit incident reports directly to NIPC,
including the Energy ISAC and its members, which, according to an ISAC
official, transmit incident reports via its secure CIP information
system, InfraGard, or other means.
Federal lead agencies for the industry sectors covered by our review
also noted efforts to develop relationships and encourage information-
sharing and partnering with the ISACs. For example, the Department of
Energy reports that it maintains daily contact with officials from both
the Energy and the Electricity ISACs, to exchange appropriate sensitive
information. Further, in order to share appropriate classified threat
information, the department reports that its Office of Energy Assurance
has obtained clearances for more than 300 persons, including staff for
both ISACs as well as officials of various oil, natural gas, and
electric power firms.[Footnote 37] This office also works closely with
NIPC and the National Joint Terrorism Task Force. As another example,
Commerce‘s NTIA reports that since the release of PDD 63 in 1998, its
Communications and Information Infrastructure Assurance Program has
focused on working closely with the private sector to develop and
implement a vulnerability awareness and education program for the
information and communications sector, to facilitate industry-
government cooperation on CIP research and development, and to support
a growing CIP international outreach program.
Concerning the support provided by their lead agencies, officials
representing four of these ISACs--Telecommunications, Information
Technology, Water, and Electricity--said that they had good working
relationships with their lead agencies. For example, Electricity stated
that it has an excellent relationship with the Department of Energy. In
contrast, the Energy ISAC expressed concerns with the Department of
Energy‘s lack of clear support in creating the ISAC and with the high
turnover in the agency liaison position. The other lead agencies--the
National Communications System, Commerce, and EPA--all reported good
working relationships with their ISACs. The Department of Energy
reported that it is taking steps to improve the current information-
sharing process, which included assigning three additional analysts
from its Office of Energy Assurance to support NIPC.
CIAO‘s Agency Assistance Focuses on Project Matrix:
According to PDD 63, the CIAO is required to coordinate analyses of the
federal government‘s own dependencies on critical infrastructures. As
discussed previously, to assist the agencies in protecting their own
critical assets, this office has provided guidance, including its
Vulnerability Assessment Framework and its Practices for Securing
Critical Information Assets. In addition, in March 2000 it began
assisting the agencies in implementing its Project Matrix methodology
to identify their critical assets and these assets‘ dependencies on
other government assets and private-sector infrastructures--assistance
the agencies we reviewed agreed was needed to help them identify assets
of national importance.
Currently, CIAO provides assistance in applying Project Matrix in the
form of teams that help the agencies conduct step 1 of the methodology
and plans to assist in conducting Project Matrix step 2 analyses for
two assets at each agency. In addition, as mentioned previously, CIAO
is also currently revising and streamlining its Project Matrix
methodology to consolidate some steps and make it less labor intensive
for the agencies.
PDD 63 Implementation Presents Challenges and Obstacles:
The agencies and organizations identified challenges and obstacles that
could adversely affect their efforts to protect their critical
infrastructures. These challenges and obstacles are primarily ensuring
adequate CIP resources, coordinating security activities for agencies‘
critical assets, and having ISACs share information with the federal
government.
Agencies Report Challenges in Justifying CIP Resources:
All the agencies we reviewed have received increased CIP funding in
recent years. However, they also noted that there will be continuing
challenges to obtain the funding needed to protect their critical
assets.
Like many agencies, the four we reviewed do not receive appropriations
specifically designated for CIP, but do collect information and data on
their CIP programs and report them to OMB as part of its national
security crosscut data call, from which it prepares its annual report
to the Congress on combating terrorism. OMB‘s October 2001 guidance to
the agencies for the national security crosscut contains detailed
instructions on identifying and categorizing CIP activities, including
identifying agency systems that are mission critical on a national
level, not just an agency level; designating whether activities pertain
to internal agency critical infrastructures or to the critical
infrastructure sectors identified in PDD 63; and identifying specific
critical infrastructure program areas, such as threat/
vulnerability/risk assessments and education and training. In addition,
the guidance gave instructions for allocating activities among multiple
sectors and distinguishing between cyber and physical activities. It
also recognized potential overlap with data reported for other portions
of the data call, such as a physical security activity being counted as
part of both the CIP and combating terrorism data.
Although there are differences in the way these four agencies report
their CIP spending, the data they reported to OMB for its June 2002
report showed significant overall increases in CIP funding for fiscal
years 2002 and 2003 as compared with fiscal year 2001.[Footnote 38]
These data are summarized in table 9.
Table 9: Critical Infrastructure Spending by the Departments of
Commerce, Energy, and Health and Human Services and the Environmental
Protection Agency (Fiscal Years 2001-2003, Dollars in Millions):
Agency: Commerce[ A]; Fiscal year 2001
(actual): $27.9; Fiscal year 2002
(enacted): $30.1; Fiscal year 2002 supplemental
(enacted): $10.3; Fiscal year 2003
(budget): $50.7.
Agency: Energy; Fiscal year 2001
(actual): 48.4; Fiscal year 2002
(enacted): 46.3; Fiscal year 2002 supplemental
(enacted): 0.0; Fiscal year 2003
(budget): 71.8.
Agency: EPA; Fiscal year 2001
(actual): 2.2; Fiscal year 2002
(enacted): 3.4; Fiscal year 2002 supplemental
(enacted): 121.0; Fiscal year 2003
(budget): 41.7.
Agency: HHS; Fiscal year 2001
(actual): 84.3; Fiscal year 2002
(enacted): 96.8; Fiscal year 2002 supplemental
(enacted): 0.0; Fiscal year 2003
(budget): 87.2.
Agency: Total; Fiscal year 2001
(actual): $162.8; Fiscal year 2002
(enacted): $176.5; Fiscal year 2002 supplemental
(enacted): $131.3; Fiscal year 2003
(budget): $251.3.
Source: OMB‘s Annual Report to Congress on Combating Terrorism, June
2002.
Note: Totals may not add because of rounding, and we did not validate
the accuracy of reported amounts.
[A] Includes funding to support operations of Commerce‘s National CIAO.
[End of table]
As this table shows, CIP funding for these four agencies increased from
$162.8 million in fiscal year 2001 to $176.5 million in fiscal year
2002 (an increase of $13.7 million, or 8 percent). An emergency
response supplemental appropriation in 2002 following the September 11,
2001, attacks added an additional $131.3 million, of which $119 million
was for EPA to provide additional physical security for its facilities
and to assist utilities in conducting vulnerability assessments for
large drinking water systems. Including the supplemental, spending
enacted for fiscal year 2002 totaled $307.8 million--an increase of
$145.0 million, or 89 percent, compared with fiscal year 2001. For
fiscal year 2003, CIP funding for the four agencies totaled $251.3
million--$56.5 million less than the total for fiscal year 2002 and the
supplemental, but still an increase of $88.5 million, or 54 percent,
compared with fiscal year 2001.
Although most of the agencies we reviewed received significant
additional CIP appropriations for fiscal years 2002 and 2003, agencies
noted the following examples of challenges in obtaining CIP funding:
* In June 2001, the EPA IG reported that the agency‘s participation in
Project Matrix had been delayed since February 2001 because of
insufficient funding. Further, the OIG reported that OMB denied without
comment EPA‘s fiscal year 2001 request for $5 million for physical
measures under PDD 63.
* Officials in Commerce‘s Office of the CIO said that the department‘s
fiscal year 2001 budget request included $79 million to perform
vulnerability assessments, mitigate vulnerabilities, and train
employees. However, according to these officials, OMB denied the
request because it was not based on completed vulnerability assessments
and detailed remediation plans. Further, they said that the
department‘s fiscal year 2002 budget request included amounts in each
operating unit‘s budget to perform vulnerability assessments, with a
plan to request the mitigation funding in fiscal year 2003. However,
the department denied the requested funding for the planned assessments
and for virtually all the mitigation efforts because, according to a
Commerce Office of Budget official, OMB guidance directed that only
requests for current service levels could be submitted.
* Officials in Energy‘s Office of Security stated that OMB had denied
$16 million for security that the department had requested as part of a
fiscal year 2002 supplemental. In a March 28, 2002, letter to OMB, the
Director of Energy‘s Office of Management, Budget, and Evaluation/Chief
Financial Officer said that the denial of this request had left the
department with inadequate funds to implement security measures that
would appropriately respond to the terrorist attacks of September 11,
2001. According to this letter, OMB denied the supplemental security
proposals because of the pending revision of Energy‘s Design Basis
Threat, a document that outlines the basis for physical security
measures.[Footnote 39]
Resources will be needed for the agencies to complete their Project
Matrix efforts and for other CIP activities related to their critical
assets, including conducting and updating vulnerability assessments,
correcting identified vulnerabilities, and preparing and updating
continuity of operations plans. In part, the Project Matrix reviews
themselves may help the agencies prioritize and justify their CIP
spending. OMB is requiring all large agencies to undergo a Project
Matrix review to more clearly identify and prioritize the security
needs for government assets. In addition, OMB identifies these reviews
as a key element in its efforts to identify the critical operations and
assets of the federal government‘s critical enterprise architecture and
to better prioritize and fund the government‘s security needs.
Agencies Face Challenges Coordinating CIP Efforts:
With responsibilities for the security of cyber and physical assets
assigned to the CIOs and chief infrastructure assurance officers,
respectively, and to separate agency organizations, several of the
agencies noted challenges in coordinating efforts internally to
identify and protect their critical assets. In addition, we identified
a challenge in coordinating critical asset protection with GSA, which
provides protective services for many agencies‘ facilities or
buildings.
As discussed previously, three of the four agencies had security
responsibilities for cyber assets assigned to the CIO, with
responsibilities for physical assets assigned to a separate chief
infrastructure assurance officer in another organization. For example,
at EPA, the Office of Environmental Information, which houses the
agency‘s CIO, was responsible for cyber security, and the Office of
Administration and Resources Management was responsible for physical
security. At Commerce, as permitted by PDD 63, the CIO was also
designated the chief infrastructure assurance officer and, thus, was
responsible for both cyber and physical assets; the department also
maintained a separate office of security that was responsible for
physical security.
Officials at the agencies noted varying levels of coordination between
the organizations responsible for cyber and physical security,
including coordination on an as-needed basis, with no formal process at
EPA; a formal memorandum of agreement on the review of cybersystems at
Commerce; and weekly cyber security coordination meetings held at
Energy with representatives from the Office of the CIO, the Office of
Security, the Office of Independent Oversight and Performance
Assurance, and the IG. Despite these coordination mechanisms, their
efforts to identify and protect their critical assets highlighted
coordination challenges that the agencies are addressing. For example,
our initial discussions with an official in Commerce‘s Office of
Security indicated that coordination of security matters between that
office and the office of the CIO was a problematic and ongoing issue.
However, the Director of Security, who was appointed in August 2002,
and the CIO office‘s Information Technology Security Program Manager
report that these offices are now working to establish an integrated
approach to security matters, including CIP and continuity-of-
operations planning. As another example, for critical assets at HHS,
there were inconsistencies between the physical vulnerability
assessment dates maintained by the CIO‘s office and those maintained by
the office responsible for physical security--discrepancies that were
not identified until prompted by our request for updated data.
Our analyses also identified an external coordination challenge with
GSA, which may often be responsible for protecting agency facilities or
buildings that house critical assets. According to GSA officials, they
are not aware of whether a critical asset is in one of the facilities
they manage unless the agency specifically shares that information--
something GSA expects the agencies to do during GSA‘s vulnerability
assessment process. However, this information is not always shared, and
in one instance HHS officials confirmed that GSA had not been informed
that an HHS critical asset was housed within a GSA-owned building. GSA
officials agreed that knowing whether facilities or their assets are
considered critical could affect the level of security it provides, and
it also indicated that this may be something that GSA should routinely
inquire about as part of its vulnerability assessment process.
ISACs Face Information-Sharing Challenges:
Officials for the five ISACs we contacted noted numerous challenges
that could affect their establishment and operation, but they most
often identified FOIA as a major challenge that hinders the sharing of
intelligence and incident information between infrastructure sectors
and the federal government. Two ISACs also identified sharing
information among industry partners as a challenge because such
cooperation could open companies to prosecution under antitrust
regulations. Options being considered and actions taken to help
overcome these challenges include restrictions on government use and
disclosure of critical infrastructure information, such as those
included in the recently enacted Homeland Security Act of 2002, as well
as the use of public policy tools to provide incentives.
The range of challenges identified by the ISACs included convincing
businesses of their value and benefit; overcoming members‘ mistrust of
government; not having a standard model to follow; setting up a limited
liability corporation; finding a contractor with the proper information
technology security controls to ensure that data are protected;
obtaining security clearances to enable the sharing of classified
information with ISAC staff who have a ’need to know,“ and ensuring
secure communications for sharing this information; and providing for
communication outside of the public switched network, such as satellite
phones. In addition, according to the Telecommunications Infrastructure
ISAC, the chief concern of its members is the issue of liability
associated with reporting a problem involving another company. Such
challenges may affect member participation and the amounts of
information shared by both the members and the government. For one
challenge in particular--providing security clearances--officials for
NIPC stated that NIPC is taking actions to expedite clearances, and its
goal is to establish security clearances to one or two members of the
managing board for each ISAC. An official for the Electricity ISAC
noted that security clearances have been provided to several subject
matter experts in the sector, but he also stressed the importance of
ensuring secure communications for those holding clearances either
through the ISAC itself or through access to federal secure
communications facilities.
One challenge reported by all five ISACs, however, was the concern
about reporting incident information that could be subject to FOIA
requests. In addition, two reported that their members are concerned
about the risk of prosecution under antitrust regulations for sharing
information with other industry partners--a concern also acknowledged
in the National Strategy for Homeland Security and by NIPC in a July
2002 congressional testimony.[Footnote 40] As mentioned previously, an
Energy ISAC official stated that it does not plan to share information
with the federal government until these issues are resolved, and some
ISAC officials suggested that existing FOIA and antitrust legislation
be modified to provide specific exemptions for reported incident
information.
The July 2002 National Strategy for Homeland Security includes
’enabling critical infrastructure information sharing“ among 12 major
legislative initiatives it outlines and states that the nation must
meet this need by narrowly limiting public disclosure of information
relevant to protecting our physical and cyber critical infrastructures
in order to facilitate its voluntary submission. This strategy states
that the Attorney General will convene a panel to propose any legal
changes necessary to enable the sharing of essential homeland security-
related information between the federal government and the private
sector. In addition, we have testified on the continuing debate
concerning the protections provided to private-sector entities as they
are encouraged to disclose and exchange information on both physical
and cyber security problems and solutions that are essential to
protecting our nation‘s critical infrastructures.[Footnote 41]
In response to some of these concerns, the Congress included provisions
in the Homeland Security Act of 2002 that restrict federal, state, and
local government use and disclosure of critical infrastructure
information that has been voluntarily submitted to the Department of
Homeland Security. These restrictions include an exemption from
disclosure under FOIA, a general limitation on use to CIP purposes, and
limitations on use in civil actions and by state or local governments.
The act also provides penalties:
for any federal employee who improperly discloses any protected
critical infrastructure information. At this time, it is too early to
tell what impact the new law will have on the willingness of the
private sector to share critical infrastructure information.
In addition to legislation, public policy tools have also been
discussed and used as another approach to encouraging increased
private-sector CIP efforts and information sharing with the federal
government. In his June 2002 testimony on the then-proposed Department
of Homeland Security, the Comptroller General noted that intelligence
and information-sharing challenges highlight the need for strong
partnerships with those outside the federal government, and that the
new department would need to design and manage tools of public policy
to engage and work constructively with third parties.[Footnote 42]
Further, the National Strategy for Homeland Security discusses the need
to use available policy tools to raise the security of our critical
infrastructures, and it specifically mentions federal grants programs
to assist state and local efforts and legislation to create incentives
for the private sector. Public policy tools available to governments
include grants, regulations, tax incentives, and regional coordination
and partnerships, and some of these are already being used. For
example, as the lead agency for the water sector, EPA reported
providing 449 grants totaling $51 million to assist utilities for large
drinking water systems in preparing vulnerability assessments,
emergency response/operating plans, security enhancement plans and
designs, or a combination of these efforts. In a different approach,
the American Chemistry Council, the ISAC for the chemical sector,
requires that as a condition of membership, its members perform
enhanced security activities, including vulnerability assessments.
Conclusions:
Although recent executive orders and national strategies reemphasize
the importance of CIP, efforts to fully implement PDD 63 requirements
for protecting agencies‘ critical assets and enhancing information
sharing through voluntary private-sector ISACs are not quickly
achieving the results necessary to protect major sectors of our
nation‘s critical infrastructure in a post-September 11th environment.
The agencies have made progress in implementing PDD 63 requirements,
and most have tentatively identified or are revisiting their list of
critical assets. Further, CIAO is currently undertaking efforts to
streamline its Project Matrix methodology. However, with no established
agency or government milestones and with resource uncertainties, it is
difficult to estimate when the agencies will complete the process of
identifying their critical assets and dependencies. This difficulty
also creates uncertainties as to when other key steps in protecting
critical assets will be completed--steps that are not routinely tracked
from both a cyber and physical perspective for critical assets, such as
identifying their vulnerabilities, developing remediation plans, and
developing plans to ensure the continuity of critical operations. Other
agencies, such as GSA, are also a critical element in this process to
ensure that once critical assets are identified, appropriate security
is provided for the facilities and buildings that house them. Further,
identifying critical assets and taking the other key steps needed to
protect them can help the agencies identify and obtain required
resources. Until these processes and steps are completed, neither the
agencies nor the federal government can ensure that the operations and
infrastructures essential to national security, national economic
security, and national public health and safety are safeguarded against
attack and could be rapidly reconstituted if a successful
infrastructure attack or disruption were to occur.
The five ISACs have made progress in establishing ISAC operations.
However, mixed progress in suggested activities and other challenges
and obstacles they reported potentially limit their ability to gather
incident information and disseminate it between their industry sectors
and the federal government. This potential limitation could affect
NIPC‘s efforts to provide timely warning information for the government
and other industry sectors. NIPC and the lead agencies continue to work
with the ISACs to improve the public/private partnership called for by
PDD 63 and subsequent federal plans and strategies. The Homeland
Security Act of 2002, in part, responds to the ISACs‘ FOIA concern by
including information use and disclosure restrictions. However, it
remains to be seen whether these efforts will result in increased
information sharing with the federal government and whether additional
federal actions, such as the use of public policy tools, could offer
potential incentives to encourage increased private-sector CIP efforts.
Given what we found for these selected agencies and ISACs, we believe
that it is crucial that the administration also know the status and
progress of CIP activities for all major federal agencies and critical
infrastructure sectors.
Recommendations for Executive Action:
To (1) help ensure the identification and adequate protection of
critical agency cyber-based and physical assets and (2) reinforce
management‘s commitment to prioritize the protection of critical
infrastructure throughout agencies, we recommend that the Secretaries
of Commerce, Energy, and Health and Human Services and the
Administrator of the Environmental Protection Agency all direct their
respective CIOs and chief infrastructure assurance officers to work
together, as appropriate, to:
* coordinate with CIAO to set milestones to complete their Project
Matrix analyses that will identify each agency‘s critical cyber,
physical, and other assets and the dependencies of these assets on
other government operations and privately owned critical
infrastructures;
* require, concurrently with the identification of critical assets and
their dependencies, that vulnerability assessments be conducted or
updated where warranted, to appropriately consider (1) the specific
assets identified as critical national assets and their dependencies,
(2) both cyber and physical vulnerabilities of these assets, and
(3) changes in the threat environment, particularly as reflected by
recent terrorist activity and in warnings by the Office of Homeland
Security and NIPC;
* ensure that remediation plans for correcting identified critical
asset vulnerabilities are developed, specifying corrective actions and
the time lines, responsibilities, and funding for their implementation;
and that cyber-related actions are also reflected in the agency‘s
information security corrective-action plans, and that updates are
reported to OMB;
* ensure that agency continuity-of-operations plans are prepared or
updated to incorporate critical assets and, according to the CIAO
criterion, that they provide for the reconstitution of these assets
within 72 hours of a successful infrastructure attack or disruption;
* routinely track and monitor the status of vulnerability assessments,
corrective actions, and other security efforts related to critical
assets, such as the development of continuity-of-operations plans; and
provide an annual status update to help support budget requests and
other reporting requirements, such as those of the Government
Performance and Results Act and the Federal Information Security
Management Act;
* formally apprise the General Services Administration when facilities
or buildings for which it has protective responsibilities house agency-
critical assets identified through the Project Matrix process; and:
* use Project Matrix plans and results to help prioritize and prepare
budget justifications for resources needed to identify and protect the
agency‘s own critical infrastructures.
To help ensure that private-sector ISACs continue efforts to improve
their CIP activities, we recommend that the Secretary of Energy, the
Secretary of Commerce, and the Administrator of the Environmental
Protection Agency, through their lead agency responsibilities for the
energy, electricity, information, communication, and water industry
sectors, assess the need for grants, tax incentives, regulation, or
other public policy tools to encourage increased private-sector CIP
activities and greater sharing of intelligence and incident information
between the sectors and the federal government. After lead agency
responsibilities for the information and telecommunications sector are
transitioned to the Department of Homeland Security, the Secretary of
that department would become responsible for this recommendation for
that sector.
To assist the administration in establishing CIP priorities for all
major federal agencies, critical infrastructure sectors, and the
Department of Homeland Security, we further recommend that:
* the Director of the Critical Infrastructure Assurance Office
determine the status of, and identify additional actions needed to
improve the federal government‘s efforts and progress in implementing,
federal CIP policy, including identifying the federal government‘s
critical assets, completing vulnerability assessments for these assets,
remedying identified vulnerabilities, and incorporating these assets
into continuity of operations plans; and:
* the Director of the National Infrastructure Protection Center
determine the status and identify additional actions needed to improve
the quality and quantity of information being provided by the ISACs,
and of plans made by the new department‘s Information Analysis and
Infrastructure Protection directorate and the ISACs to enhance the
current information-sharing process.
These organizations should coordinate the implementation of these
recommendations with the Department of Homeland Security, which is
responsible for developing the comprehensive national plan and will
become responsible for the recommendations as the organizations
transition to the department.
Agency Comments and Our Evaluation:
The Inspector General for the Department of Health and Human Services
transmitted the department‘s written comments on a draft of this report
(see app. I). The department concurred with our recommendations for
executive agencies and noted that, in many cases, it is already engaged
in the recommended activities. Also, in responding to our
recommendation that agencies ensure that their continuity-of-
operations plans are prepared or updated to incorporate critical assets
and provide for the reconstitution of these assets within 72 hours of a
successful infrastructure attack or disruption, the department
commented that its physical security officials will work closely with
its Continuity of Operations Plan program to ensure that all critical
assets are included in the 72-hour recovery plan. Regarding our
recommendation that agencies formally apprise GSA when facilities or
buildings for which it has protective responsibilities house agency-
critical assets, the department commented that physical security
officials would coordinate with GSA/Federal Protective Service on
updating the list of CIP sites. We also received written and oral
technical comments from the Department of Commerce‘s CIAO and its
National Telecommunications and Information Administration, EPA, HHS,
the FBI, the National Communications System, the North American
Electric Reliability Council, the Association of Metropolitan Water
Agencies, and the Energy and Information Technology ISACs. Comments
from all these organizations have been incorporated into the report, as
appropriate.
:
As agreed with your staff, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it until 30
days from the date of this letter. At that time, we will send copies of
this report to other interested congressional committees and the heads
of the agencies discussed in this report, as well as to the private-
sector participants and other relevant agencies. In addition, the
report will be available at no charge on the GAO Web site at http://
www.gao.gov.
If you or your offices have any questions about matters discussed in
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 or rittw@gao.gov, respectively. Staff who made key
contributions to this report are listed in appendix II.
Robert F. Dacey
Director, Information Security Issues:
Signed by Robert F. Dacey:
[End of section]
Appendixes:
Appendix I: Comments from the Department of Health and Human Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
JAN 27 2003:
Mr. Robert F. Dacey:
Director, Information Security Issues United States General:
Accounting Office Washington, D.C. 20548:
Dear Mr. Dacey:
Enclosed are the department‘s comments on your draft report entitled,
’Critical Infrastructure Protection: Challenges for Selected Agencies
and Industry Sectors.“ The comments represent the tentative position of
the department and are subject to reevaluation when the final version
of this report is received.
The department also provided several technical comments directly to
your staff.
The department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Janet Rehnquist Inspector General:
Signed by Janet Rehnquist:
Enclosure:
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. The OIG has not conducted an independent assessment of these
comments and therefore expresses no opinion on them.
Comments of the Department of Health and Human Services to the General
Accounting Office‘s Draft Report, ’Critical Infrastructure Protection:
Challenges for Selected Agencies and Industry Sectors“ (GAO-03-233):
General Comments:
The Department of Health and Human Services (HHS) appreciates the
opportunity to comment on this draft report.
GAO Recommendations for Executive Action:
To (1) help ensure the identification and adequate protection of
critical agency cyber-based and physical assets and (2) reinforce
management‘s commitment to prioritize the protection of critical
infrastructure throughout agencies, we recommend that the Secretaries
of Commerce, Energy, Health and Human Services, and the Administrator
of the Environmental Protection Agency each direct their CIOs and chief
infrastructure assurance officers to work together, as appropriate, to:
* Coordinate with CIAO to set milestones to complete their Project
Matrix analyses that will identify the agency‘s critical cyber,
physical, and other assets; and the dependencies of these assets on
other government operations and privately owned critical
infrastructures:
Concurrent with the identification of critical assets and their
dependencies, require that vulnerability assessments be conducted or
updated where warranted to appropriately consider (1) the specific
assets identified as critical national assets and their dependencies;
(2) both cyber and physical vulnerabilities of these assets; and (3)
changes in the threat environment, particularly as reflected by recent
terrorist activity and in warnings by the Office of Homeland Security
and NIPC:
* Ensure that remediation plans for correcting identified critical
asset
vulnerabilities are developed, specifying corrective actions and the
timelines, responsibilities, and funding for their implementation, and
that those actions that are cyber-related are also reflected in the
agency‘s information security corrective action plans and updates
reported to OMB:
* Ensure that agency continuity of operations plans are prepared or
updated to incorporate critical assets and, according to CIAO
criterion, provide for reconstitution of these assets within 72 hours
of a successful infrastructure attack or disruption:
* Routinely track and monitor the status of vulnerability assessments,
corrective actions, and other security efforts related to critical
assets, such as the development of continuity of operations plans; and
provide an annual status update to help support budget requests and
other reporting requirements, such as:
those of the Government Performance and Results Act and the Federal
Information Security Management Act:
* Formally apprise the General Services Administration when facilities
or buildings for which it has protective responsibilities house agency
critical assets identified through the Project Matrix process:
* Use Project Matrix plans and results to help prioritize and prepare
budget justifications for resources needed to identify and protect the
agency‘s own critical infrastructures.
HHS Response:
The HHS concurs with GAO‘s recommendations for executive agencies. In
many cases, we already are engaged in the recommended activities.
In terms of our response to specific recommendations: GAO was concerned
that HHS has not provided for immediate reconstitution of critical
assets. The HHS Physical Security officials will work closely with the
Continuity of Operations Plan program to ensure all critical assets are
included in the 72 hours recovery plan. Also, GAO was concerned that
HHS was not coordinating with the General Services Administration (GSA)
on the identification of HHS critical assets that are housed in GSA
buildings. The HHS Physical Security officials will coordinate with
GSA/Federal Protective Service on updating the list of Critical
Infrastructure Protection sites.
[End of section]
Appendix II GAO Contact and Staff Acknowledgments:
GAO Contact:
William B. Ritt, (202) 512-6443:
Acknowledgments :
In addition to the person named above, Shirley Bates, Elena Epps,
Joanne Fiorino, Sophia Harrison, Danielle Hollomon, Barbarol James,
David Powner, Jamie Pressman, Jamelyn Smith, Jessica Steele, Cady
Summers, Larry Turman, and Kathleen Turner made key contributions to
this report.
(310177):
FOOTNOTES
[1] Computer Security Institute, ’2002 Computer Crime and Security
Survey,“ Computer Security Issues & Trends, volume VIII, no. 1, Spring
2002.
[2] ’Administrative Oversight: Are We Ready for A CyberTerror Attack?“
Testimony before the Senate Committee on the Judiciary, Subcommittee on
Administrative Oversight and the Courts, by Richard A. Clarke, Special
Advisor to the President for Cyberspace Security and Chairman of the
President‘s Critical Infrastructure Protection Board (Feb. 13, 2002).
[3] Testimony of Richard D. Pethia, Director, CERT Centers, Software
Engineering Institute, Carnegie Mellon University, before the House
Committee on Government Reform, Subcommittee on Government Efficiency,
Financial Management and Intergovernmental Relations, November 19,
2002.
[4] National Infrastructure Protection Center, Swarming Attacks:
Infrastructure Attacks for Destruction and Disruption (July 2002).
[5] Fourth Annual Report to the President and the Congress of the
Advisory Panel to Assess Domestic Response Capabilities for Terrorism
Involving Weapons of Mass Destruction-IV. Implementing the National
Strategy (Dec. 15, 2002).
[6] America Still Unprepared--America Still in Danger, Report of an
Independent Task Force Sponsored by the Council on Foreign Relations,
released October 2002.
[7] President‘s Commission on Critical Infrastructure Protection,
Critical Foundations: Protecting America‘s Infrastructures (October
1997).
[8] PDD 63 created a National Plan Coordination staff responsible for
these tasks that, according to CIAO officials, evolved into CIAO.
[9] Executive Order 13231 replaces this council with the National
Infrastructure Advisory Council.
[10] The White House, Defending America‘s Cyberspace: National Plan for
Information Systems Protection: Version 1.0: An Invitation to a
Dialogue (Washington, D.C.: January 2000).
[11] Office of Homeland Security, the White House, National Strategy
for Homeland Security (July 2002).
[12] NIPC currently reports that 12 ISACs have been formed, including
those for the chemicals industry, surface transportation, electric
power, telecommunications, information technology, financial services,
water supply, oil and gas, emergency fire services, food, emergency law
enforcement, and interstate.
[13] The White House, National Strategy to Secure Cyberspace
(Washington, D.C.: February 2003); and National Strategy for the
Physical Protection of Critical Infrastructures and Key Assets
(Washington, D.C.: February 2003).
[14] U.S. General Accounting Office, Information Security:
Opportunities for Improved OMB Oversight of Agency Practices., GAO/
AIMD-96-110 (Washington, D.C.: Sept. 24, 1996).
[15] U.S. General Accounting Office, Information Security: Serious
Weaknesses Place Critical Federal Operations Assets at Risk, GAO/AIMD-
98-92 (Washington, D.C.: Sept. 23, 1998); Information Security: Serious
and Widespread Weaknesses Persist at Federal Agencies,GAO/AIMD-00-295
(Washington, D.C.: Sept. 6, 2000); and Computer Security: Improvements
Needed to Reduce Risk to Critical Federal Operations and Assets, GAO-
02-231T (Washington, D.C.: Nov. 9, 2001).
[16] GAO/HR-97-9 and GAO-01-263.
[17] U.S. General Accounting Office, Computer Security: Progress Made,
But Critical Federal Operations and Assets Remain at Risk, GAO-03-303T
(Washington, D.C.: Nov. 19, 2002).
[18] U.S. General Accounting Office, Combating Terrorism: Selected
Challenges and Related Recommendations, GAO-01-822 (Washington, D.C.:
Sept. 20, 2001).
[19] The PCIE primarily is composed of the presidentially appointed
inspectors general, and the ECIE is primarily composed of the agency-
head-appointed inspectors general. In November 1999, PCIE and ECIE
formed a working group to review the adequacy of federal agencies‘
implementation of PDD 63. The March 2001 report is based on reviews by
21 inspectors general of their respective agencies‘ PDD 63 planning and
assessment activities.
[20] Title X, Subtitle G--Government Information Security Reform, Floyd
D. Spence National Defense Authorization Act for Fiscal Year 2001, P.L.
106-398 (Oct. 30, 2000). GISRA has been superseded by the Federal
Information Security Management Act, enacted on December 17, 2002, as
Title III of the E-Government Act of 2002.
[21] U.S. General Accounting Office, Information Security: Additional
Actions Needed to Fully Implement Reform Legislation, GAO-02-470T
(Washington, D.C.: Mar. 6, 2002).
[22] Office of Inspector General, U.S. Department of Energy, Cyber-
Related Critical Infrastructure Identification and Protection
Measures, DOE/IG-0545 (Mar. 20, 2002).
[23] Critical Infrastructure Assurance Office, Practices for Securing
Critical Information Assets (January 2000).
[24] The Federal Computer Incident Response Center provides a central
focal point for incident reporting, handling, prevention, and
recognition for the federal government. Its purpose is to ensure that
the government has critical services available in order to withstand or
quickly recover from attacks against its information resources.
[25] Vulnerability Assessment Framework 1.1, prepared by KPMG Peat
Marwick LLP for the Critical Infrastructure Assurance Office (October
1998).
[26] The framework identified two levels of critical organizations,
personnel, systems, and facilities, or Minimum Essential Infrastructure
(MEI), to be considered and assessed: (1) the national MEI, which
provides a flow of goods and services that are absolutely essential to
the economic well-being and national security of the United States, to
the smooth functioning of governments at all levels, and to society as
a whole, and (2) the agency MEI, which provides the inputs and outputs
necessary to support the core processes essential to accomplishing an
organization‘s core mission as they relate to national security,
national economic security, or continuity of government services.
[27] GAO-01-822.
[28] Office of Management and Budget, FY 2001 Report to Congress on
Federal Government Information Security Reform (February 2002).
[29] CIAO also reported that two other agencies found no candidate
assets to undergo a step 1 process.
[30] National Institute of Standards and Technology, Risk Management
Guide for Information Technology Systems, Special Publication 800-30,
October 2001.
[31] U.S. Marshals Service, Department of Justice, Vulnerability
Assessment of Federal Facilities (June 28, 1995).
[32] Commerce had not yet identified its critical assets, but for its
42 identified candidate assets, Commerce-provided data indicated that
not all had current cyber and physical vulnerability assessments.
[33] U.S. General Accounting Office, Information Security: Weaknesses
Place Commerce Data and Operations at Serious Risk, GAO-01-751
(Washington, D.C.: Aug. 13, 2001), and Information Security:
Fundamental Weaknesses Place EPA Data and Operations at Risk, GAO/AIMD-
00-215 (Washington, D.C.: July 6, 2000).
[34] PDD 67, Enduring Constitutional Government and Continuity of
Government Operations, issued October 21, 1998, required federal
agencies to develop continuity of operations plans for essential
operations. According to guidance issued by the Federal Emergency
Management Agency (Federal Preparedness Circular 65, July 26, 1999),
these plans are to provide for continued performance of essential
federal functions under all circumstances.
[35] Generally, FOIA (5 U.S.C. § 552) provides persons with the right
of access to a broad range of federal agency records.
[36] U.S. General Accounting Office, Critical Infrastructure
Protection: Significant Challenges in Developing National
Capabilities, GAO-01-323 (Washington, D.C.: Apr. 25, 2001).
[37] The Office of Energy Assurance and its functions are to transition
to the Department of Homeland Security.
[38] Office of Management and Budget, Annual Report to Congress on
Combating Terrorism (June 2002).
[39] The Design Basis Threat for the Department of Energy identifies
and characterizes potential adversary threats to its programs and
facilities in order to protect against activities including
unauthorized access; theft, diversion, or loss of control of nuclear
weapons, weapons components, special nuclear material, associated
technologies and hardware, and critical technologies; sabotage;
espionage; loss or theft of classified material or government property;
and other acts that may cause unacceptable adverse impacts on national
security, the health and safety of employees, the public, or the
environment. Among other things, the Design Basis Threat is used to
develop safeguards and security programs and requirements and to
provide a basis for site safeguards and security program planning,
implementation, and facility design.
[40] Testimony of Ronald Dick, Director, National Infrastructure
Protection Center, Federal Bureau of Investigation, before the House
Committee on Government Reform, Subcommittee on Government Efficiency,
Financial Management and Intergovernmental Relations, July 24, 2002.
[41] U.S. General Accounting Office, Critical Infrastructure
Protection: Significant Challenges Need to Be Addressed, GAO-02-961T
(Washington, D.C.: July 24, 2002).
[42] U.S. General Accounting Office, Homeland Security: Proposal for
Cabinet Agency Has Merit, But Implementation Will Be Pivotal to
Success, GAO-02-886T (Washington, D.C.: June 25, 2002).
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