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July 10, 2007: 

The Honorable Bennie G. Thompson: 
Chairman: 
Committee on Homeland Security: 
House of Representatives: 

The Honorable Sheila Jackson-Lee: 
Chairwoman: 
Subcommittee on Transportation Security and Infrastructure Protection: 
Committee on Homeland Security: 
House of Representatives: 

Subject: Critical Infrastructure Protection: Sector Plans and Sector 
Councils Continue to Evolve: 

In 2005, Hurricane Katrina devastated the Gulf Coast, damaging critical 
infrastructure, such as oil platforms, pipelines, and refineries; water 
mains; electric power lines; and cellular phone towers. The 
infrastructure damage and resulting chaos disrupted government and 
business functions alike, producing cascading effects far beyond the 
physical location of the storm. In 2004, authorities thwarted a 
terrorist plot to target financial institutions in New York. In 2005, 
suicide bombers struck London's public transportation system, 
disrupting the city's transportation and mobile telecommunications 
infrastructure. Our nation's critical infrastructures and key 
resources--including those cyber and physical assets essential to 
national security, national economic security, and national public 
health and safety--continue to be vulnerable to a wide variety of 
threats. Because the private sector owns approximately 85 percent of 
the nation's critical infrastructure and key resources--banking and 
financial institutions, telecommunications networks, and energy 
production and transmission facilities, among others--it is vital that 
the public and private sectors form effective partnerships to 
successfully protect these assets.[Footnote 1] 

The Department of Homeland Security (DHS) is a key player in these 
partnerships. The Homeland Security Act of 2002 created DHS, giving the 
department wide-ranging responsibilities for leading and coordinating 
the overall national critical infrastructure protection 
effort.[Footnote 2] The act required DHS to (1) develop a comprehensive 
national plan for securing the nation's critical infrastructures and 
key resources and (2) recommend measures to protect critical 
infrastructure and key resources. Homeland Security Presidential 
Directive 7 (HSPD-7) further defined critical infrastructure protection 
responsibilities for DHS and those federal agencies--known as sector- 
specific agencies--responsible for particular industry sectors, such as 
transportation, energy, and communications. Under HSPD-7, DHS is to 
establish uniform policies, approaches, guidelines, and methodologies 
to help ensure that critical infrastructure within and across the 17 
infrastructure sectors is protected.[Footnote 3] The directive further 
promotes the use of a risk management approach to coordinate protection 
efforts. This approach includes using risk assessments to set 
priorities for protective measures by the department; sector-specific 
agencies; tribal, state, and local government agencies and authorities 
with critical assets and resources in their jurisdiction; owners and 
operators of these assets; and other entities. 

In addition, HSPD-7 required DHS to develop a comprehensive and 
integrated plan for securing the nation's critical infrastructures that 
outlines national protection goals, objectives, milestones, and key 
initiatives necessary to fulfilling these responsibilities. In 
response, DHS developed the National Infrastructure Protection Plan 
(NIPP). Issued in June 2006, the NIPP is a base plan that is to serve 
as a road map for how DHS and other relevant stakeholders, such as 
owners and operators of key critical infrastructure, should use risk 
management principles to prioritize protection activities within and 
across sectors in an integrated, coordinated fashion. In particular, 
the NIPP--along with more detailed guidance issued by DHS--required the 
individual sector-specific agencies, working with relevant government 
and private representatives, to submit sector-specific plans to DHS by 
the end of December 2006. The plans, which were released on May 21, 
2007, were to establish the means by which the sectors will identify 
their critical assets, assess risks of terrorist attacks or other 
hazards on to these assets, assess and prioritize those assets which 
have national significance, and develop protective measures for the 
sectors. The NIPP also requires that sector-specific agencies develop 
annual reports that discuss the sectors' status in implementing the 
plans. According to the NIPP, DHS is to use these individual plans and 
reports to develop an annual cross-sector report, due each September, 
that evaluates whether gaps exist in the protection plans and actions 
to be taken to protect critical infrastructures on a national level. If 
gaps exist, DHS is to work with the sectors to address them. 

To protect critical infrastructure, the NIPP describes a partnership 
model as the primary means of coordinating government and private 
efforts. For each of the 17 sectors, the model requires formation a 
government coordinating council--composed of representatives of 
federal, state, local, or tribal agencies with purview over critical 
assets. The model encourages voluntary formation of a sector 
coordinating council--composed of representative owner-operators of 
critical assets (some of which may be state or local agencies) or 
representatives from private sector trade associations. There are 32 
coordinating councils, 17 government and 15 private sector.[Footnote 4] 
These councils create the structure through which respective groups 
from all levels of government and the private sector are to collaborate 
in developing the sector-specific plans and implementing efforts to 
protect critical infrastructure. The sector coordinating councils are 
envisioned as a primary point of contact for government to plan the 
entire range of infrastructure protection activities unique to the 
sector. In addition, the NIPP also identified cross-sector councils 
that are to promote coordination, communications, and the sharing of 
key practices across the sectors. 

This report discusses (1) the extent to which the sector-specific plans 
meet NIPP and DHS requirements, (2) the government and sector 
coordinating council members' views on the value of the plans and DHS's 
review process, and (3) the key success factors and challenges that 
sector representatives reported they encountered in establishing and 
maintaining their councils. To address these objectives, we reviewed 
the NIPP as well as the sector-specific plan guidance to ascertain the 
elements required in the plans. We obtained and reviewed 9 of the 17 
draft plans against the criteria in the NIPP and plan 
guidance.[Footnote 5] For more detail on the criteria we used, see 
enclosure I. We conducted structured interviews with representatives of 
the 17 government coordinating councils and the 15 sector coordinating 
councils to obtain views on the value of the plans and the review 
process as well as the key success factors and challenges the sectors 
reported that they had encountered in establishing and maintaining 
their councils. These interviews were conducted with lead sector- 
specific agency representatives for the 17 sectors: the departments of 
Agriculture, Defense, Energy, Health and Human Services, Homeland 
Security,[Footnote 6] the Interior, and the Treasury and the 
Environmental Protection Agency, as well as with the chairs, co-chairs, 
or steering committee members of the 15 sector coordinating councils. 
We also followed up with DHS officials to determine the status of our 
outstanding recommendations on the Protected Critical Infrastructure 
Information (PCII) program. We conducted our work from February to June 
2007 in accordance with generally accepted government auditing 
standards. 

Results in Brief: 

Although the nine sector-specific plans we reviewed generally met NIPP 
requirements and DHS's sector-specific plan guidance, eight plans did 
not address incentives the sectors would use to encourage owners to 
conduct risk assessments and some plans were more comprehensive than 
others when discussing their physical, human, and cyber assets, 
systems, and functions. Most of the plans included the required 
elements of the NIPP risk management framework, such as security goals; 
and the methods the sectors expect to use to prioritize infrastructure 
as well as to develop and implement protective programs and assess 
threats, risks, and vulnerabilities.[Footnote 7] However, some plans 
were more developed and comprehensive, depending on the maturity of the 
sector and on how the sector defines its assets and functions. While 
all of the plans described the threat analyses that the sector 
conducts, eight of the plans did not describe any incentives the sector 
would use to encourage owners to conduct voluntary risk assessments, as 
required by the NIPP. These incentives are important because a number 
of the industries in the sectors are privately owned and not regulated, 
and the government must rely on voluntary compliance with the NIPP. DHS 
officials said that the variance in the plans can primarily be 
attributed to the levels of maturity and cultures of the sectors, with 
the more mature sectors--sectors with preexisting relationships and a 
history of working together--generally having more comprehensive and 
complete plans than more newly established sectors without similar 
prior relationships. The plans also varied in how comprehensively they 
addressed not only their physical assets, systems, and 
functions,[Footnote 8] but also their human and cyber assets, systems, 
and functions, a requirement in the NIPP, because the sectors reported 
that they had differing views on the extent to which they were 
dependent on each of these assets. A comprehensive identification of 
all three categories of assets is important, according to DHS sector- 
specific plan guidance, because such an asset analysis provides the 
foundation on which to conduct risk analyses and identify the 
appropriate mix of protective programs and actions that will most 
effectively reduce the risk to the nation's infrastructure. Yet, only 
one of the plans--drinking water and water treatment systems--included 
all three categories of assets. For example, because the communications 
sector limited its definition of assets to networks, systems, and 
functions, it did not, as required by DHS plan guidance, discuss how 
human assets fit into existing security projects or are relevant to 
fill the gaps to meet the sector's security goals. DHS's Office of 
Infrastructure Protection officials acknowledged the differences in how 
comprehensive the plans are, but said that these initial plans are only 
a first step and that they will work with the sectors to address 
differences in future updates. Given the disparity in the plans, 
however, it is unclear the extent to which DHS will be able to use them 
at this point to identify security gaps and critical interdependencies 
across the sectors in order to plan future protective measures. From 
reviewing these plans, it is also unclear how far along each sector 
actually is in identifying assets, setting priorities, and developing 
activities to protect key assets. DHS officials said that to determine 
this, they will need to review the sectors' annual progress reports, 
due in this month, that are to provide additional implementation 
information. 

Representatives of the government and sector coordinating councils had 
differing views regarding the value of sector-specific plans and DHS's 
review of those plans. While 10 of the 32 council representatives we 
interviewed reported that they saw the plans as useful for the sector, 
representatives of eight councils disagreed because they believed the 
plans either did not represent a partnership among the necessary key 
stakeholders, especially the private sector, or were not valuable 
because the sector had already done so much work on its own and had 
progressed beyond the plan. For example, the government facilities 
council representative said that the plan was useful because 
relationships across the sector were established during its development 
that have resulted in enhanced coordination of previously disjointed 
security efforts. DHS's Office of Infrastructure Protection officials 
agreed that the main benefit of the plans was that the process of 
developing them helped the sectors establish relationships between the 
private sector and the government and among private sector 
stakeholders. In contrast, the representative from the nuclear 
reactors, materials, and waste sector's coordinating council said that 
because the sector's security has been robust for a long time, the plan 
only casts the security of the sector in a different light. Also, the 
drinking water and water treatment sector representative said that the 
plan did not provide added value for the sector because the sector 
already has a 30-year history of protection. DHS's Office of 
Infrastructure Protection officials acknowledged that these sectors 
have a long history of relationships with the federal government and in 
some cases have been doing similar planning efforts and said that while 
the NIPP planning process may not have been as valuable to these 
sectors, it was valuable to DHS to have plans for all critical 
infrastructure sectors. Representatives of 11 of 32 councils felt that 
the review process was too lengthy and said that they had turned in 
their plans in advance of the December 31, 2006, deadline established 
by the NIPP, but had to wait more than 5 months for the plans to be 
approved. DHS Infrastructure Protection officials agreed that the 
review process had been lengthy and that time periods allowed for the 
sectors to respond to comments were too short. The officials said this 
occurred because of the volume of work DHS had to undertake and because 
some of the sector specific agencies did not communicate well with the 
sectors since they were still learning to operate effectively with the 
private sector, treating it as an equal partner under the NIPP model. 
The officials said that they plan to refine the process as the sector- 
specific agencies gain more experience working with the private sector. 
Conversely, representatives from eight of 32 councils said the review 
process for the plans worked well, despite the time it took, and five 
council representatives were complimentary of the support they received 
from DHS. The remaining council representatives did not offer views on 
these issues. 

As we reported last year,[Footnote 9] long-standing relationships were 
frequently cited as most helpful in establishing councils. Council 
representatives for 9 of the 32 councils continued to cite preexisting 
relationships as helping them in establishing and maintaining their 
sector councils, and two sectors noted that going through the process 
of establishing the councils had, in turn, improved relationships, 
while seven said achieving the necessary participation in the council 
is a continuing challenge. For example, the dams, energy, and banking 
and finance sectors, among others, said that existing relationships 
continue to help in maintaining their councils. On the other hand, 
seven sector council representatives reported difficulty in achieving 
and maintaining sector council membership, thus limiting the ability of 
the councils to effectively represent the sector. For example, the 
public health and health care sector representative said that getting 
sector members to participate is a challenge and noted that because of 
this, the first step in implementing the sector-specific plan is to 
increase awareness about the council. In addition, 11 of the 32 council 
representatives reported continuing difficulties with sharing 
information between the public and private sectors as a challenge. 
Furthermore, 6 of the 32 council representatives expressed concerns 
about the viability of the information system--the Homeland Security 
Information Network (HSIN)--DHS intends to rely on to share information 
with the sectors about critical infrastructure issues, as well as the 
effectiveness of the Protected Critical Infrastructure Information 
(PCII) program--a program that established procedures for the receipt, 
care, and storage of information submitted to DHS. Although encouraging 
the sectors to use HSIN, DHS's Infrastructure Protection officials said 
the system does not provide the capabilities that were promised, 
including providing the level of security expected by some sectors. 
Relatedly, in April 2007, we reported that the HSIN system was built 
without appropriate coordination with other information-sharing 
initiatives.[Footnote 10] Additionally, as we have reported,[Footnote 
11] potential submitters under the PCII program continue to fear that 
the information, such as information on security vulnerabilities, could 
be inadequately protected, used for future legal or regulatory action, 
or inadvertently released. We previously recommended that, among other 
things, DHS better (1) define its critical infrastructure information 
needs and (2) explain how this information will be used to attract more 
users. DHS concurred with our recommendations. In September 2006, DHS 
issued a final rule that established procedures governing the receipt, 
validation, handling, storage, marking, and use of critical- 
infrastructure information voluntarily submitted to DHS. DHS is in the 
process of implementing our additional recommendations. 

In commenting on a draft of this report, DHS said that it could not 
provide formal agency comments in the time allowed. However, DHS 
provided technical comments that have been incorporated, as 
appropriate. 

Background: 

DHS serves as the sector-specific agency for 10 of the sectors: 
information technology; communications; transportation systems; 
chemical; emergency services; nuclear reactors, material, and waste; 
postal and shipping; dams; government facilities; and commercial 
facilities. Other sector-specific agencies are the departments of 
Agriculture, Defense, Energy, Health and Human Services, the Interior, 
the Treasury, and the Environmental Protection Agency. (See table 1 for 
a list of sector-specific agencies and a brief description of each 
sector). 

Table 1: Designated Sector-Specific Agencies and Critical- 
Infrastructure Sectors: 

Sector-specific agency: Departments of Agriculture,[A] and Health And 
Human Services, Food and Drug Administration[B]; 
Sector: Agriculture and food; 
Description: Provides for the fundamental need for food. The 
infrastructure includes supply chains for feed and crop production. 
Carries out the postharvesting of the food supply, including processing 
and retail sales. 

Sector-specific agency: Department of Defense; 
Sector: Defense industrial base; 
Description: Supplies the military with the means to protect the nation 
by producing weapons, aircraft, and ships and providing essential 
services, including information technology and supply and maintenance. 

Sector-specific agency: Department of Energy; 
Sector: Energy; 
Description: Provides the electric power used by all sectors and the 
refining, storage, and distribution of oil and gas. The sector is 
divided into electricity and oil and natural gas. 

Sector-specific agency: Department of Health and Human Services; 
Sector: Public health and health care; 
Description: Mitigates the risk of disasters and attacks and also 
provides recovery assistance if an attack occurs. The sector consists 
of health departments, clinics, and hospitals. 

Sector-specific agency: Department of the Interior; 
Sector: National monuments and icons; 
Description: Memorializes or represents monuments, physical structures, 
objects, or geographical sites that are widely recognized to represent 
the nation's heritage, traditions, or values, or widely recognized to 
represent important national cultural, religious, historical, or 
political significance. 

Sector-specific agency: Department of the Treasury; 
Sector: Banking and finance; 
Description: Provides the financial infrastructure of the nation. This 
sector consists of commercial banks, insurance companies, mutual funds, 
government-sponsored enterprises, pension funds, and other financial 
institutions that carry out transactions. 

Sector-specific agency: Environmental Protection Agency; 
Sector: Drinking water and water treatment systems; 
Description: Provides sources of safe drinking water from more than 
53,000 community water systems and properly treated wastewater from 
more than 16,000 publicly owned treatment works. 

Department of Homeland Security: 


Description: [Empty]. 

Sector-specific agency: Office of Infrastructure Protection; 
Sector: Chemical; 
Description: Transforms natural raw materials into commonly used 
products benefiting society's health, safety, and productivity. The 
chemical sector produces more than 70,000 products that are essential 
to automobiles, pharmaceuticals, food supply, electronics, water 
treatment, health, construction, and other necessities. 

Sector-specific agency: Office of Infrastructure Protection; 
Sector: Commercial facilities; 
Description: Includes prominent commercial centers, office buildings, 
sports stadiums, theme parks, and other sites where large numbers of 
people congregate to pursue business activities, conduct personal 
commercial transactions, or enjoy recreational pastimes. 

Sector-specific agency: Office of Infrastructure Protection; 
Sector: Dams; 
Description: Manages water retention structures, including levees, more 
than 77,000 conventional dams, navigation locks, canals (excluding 
channels), and similar structures, including larger and nationally 
symbolic dams that are major components of other critical 
infrastructures that provide electricity and water. 

Sector-specific agency: Office of Infrastructure Protection; 
Sector: Emergency services; 
Description: Saves lives and property from accidents and disaster. This 
sector includes fire, rescue, emergency medical services, and law 
enforcement organizations. 

Sector-specific agency: Office of Infrastructure Protection; 
Sector: Nuclear reactors, materials, and waste; 
Description: Provides nuclear power, which accounts for approximately 
20 percent of the nation's electrical generating capacity. The sector 
includes commercial nuclear reactors and non-power nuclear reactors 
used for research, testing, and training; nuclear materials used in 
medical, industrial, and academic settings; nuclear fuel fabrication 
facilities; the decommissioning of reactors; and the transportation, 
storage, and disposal of nuclear materials and waste. 

Sector-specific agency: Office of Cyber Security and Communications; 
Sector: Information technology; 
Description: Produces information technology and includes hardware 
manufacturers, software developers, and service providers, as well as 
the Internet as a key resource. 

Sector-specific agency: Office of Cyber Security and Communications; 
Sector: Communications; 
Description: Provides wired, wireless, and satellite communications to 
meet the needs of businesses and governments. 

Sector-specific agency: Transportation Security Administration; 
Sector: Postal and shipping; 
Description: Delivers private and commercial letters, packages, and 
bulk assets. The U.S. Postal Service and other carriers provide the 
services of this sector. 

Sector-specific agency: Transportation Security Administration and U.S. 
Coast Guard; 
Sector: Transportation systems; 
Description: Enables movement of people and assets that are vital to 
our economy, mobility, and security with the use of aviation, ships, 
rail, pipelines, highways, trucks, buses, and mass transit. 

Sector-specific agency: Immigration and Customs Enforcement, Federal 
Protective Service; 
Sector: Government facilities; 
Description: Ensures continuity of functions for facilities owned and 
leased by the government, including all federal, state, territorial, 
local, and tribal government facilities located in the United States 
and abroad. 

Source: NIPP, Homeland Security Presidential Directive 7, and the 
National Strategy for Homeland Security. 

[A] The Department of Agriculture is responsible for food (including 
meat, poultry, and eggs) and agriculture. 

[B] The Department of Health and Human Services, Food and Drug 
Administration, is responsible for food and other than meat, poultry, 
and egg products. 

[End of table] 

Most Sector Plans We Reviewed Met NIPP and DHS Sector-Specific Plan 
Guidance, but Varied Depending on Their Maturity and How They Define 
Their Assets: 

The nine sector-specific plans we reviewed generally met NIPP 
requirements and DHS's sector-specific plan guidance, however, the 
extent to which the plans met this guidance, and therefore their 
usefulness in enabling DHS to identify gaps and interdependencies 
across the sectors, varied depending on the maturity of the sector and 
on how the sector defines its assets, systems, and functions. As 
required by the NIPP risk management framework (see fig. 1), sector- 
specific plans are to promote the protection of physical, cyber, and 
human assets by focusing activities on efforts to (1) set security 
goals; (2) identify assets, systems, networks, and functions; (3) 
assess risk based on consequences, vulnerabilities, and 
threats;[Footnote 12] (4) establish priorities based on risk 
assessments; (5) implement protective programs; and (6) measure 
effectiveness. 

Figure 1: NIPP Risk Management Framework: 

[See PDF for Image] 

Source: Department of Homeland Security: National Infrastructure 
Protection Plan. 

[End of figure] 

In addition to these NIPP risk management plan elements outlined above 
and according to DHS's sector-specific plan guidance, the plans are 
also to address the sectors' efforts to (1) implement a research and 
development program for critical infrastructure protection and (2) 
establish a structure for managing and coordinating the 
responsibilities of the federal departments and agencies--otherwise 
known as sector-specific agencies--identified in HSPD-7 as responsible 
for critical infrastructure protection activities specified for the 17 
sectors.[Footnote 13] Most of the plans included the required elements 
of the NIPP risk management framework, such as security goals and the 
methods the sectors expect to use to prioritize infrastructure, as well 
as to develop and implement protective programs. However, the plans 
varied in the extent to which they included key information required 
for each plan element. For example, all of the plans described the 
threat analyses that the sectors conduct, but only one of the plans 
described any incentives used to encourage voluntary risk assessments, 
as required by the NIPP. Such incentives are important because a number 
of the industries in the sectors are privately owned and not regulated, 
and the government must rely on voluntary compliance with the NIPP. 
Additionally, although the NIPP called for each sector to identify key 
protective programs, three of the nine plans did not address this 
requirement. DHS officials told us that this variance in the plans can, 
in large part, be attributed to the levels of maturity and culture of 
the sectors, with the more mature sectors generally having more 
comprehensive and complete plans than sectors without similar prior 
working relationships. For example, plans for the banking and finance 
and energy sector included most of the key information required for 
each plan element. According to DHS officials, this is a result of 
these sectors' having a history and culture of working with the 
government to plan and accomplish many of the same activities that are 
being required for the sector-specific plans. Therefore, these sectors 
were able to create plans that were more comprehensive and developed 
than those of less mature sectors, such as the public health and health 
care and agriculture and food sectors. 

The plans also varied in how comprehensively they addressed their 
physical, human, and cyber assets, systems, and functions because 
sectors reported having differing views on the extent to which they 
were dependent on each of these assets, systems, and functions. 
According to DHS's sector-specific plan guidance, a comprehensive 
identification of such assets is important because it provides the 
foundation on which to conduct risk analysis and identify the 
appropriate mix of protective programs and actions that will most 
effectively reduce the risk to the nation's infrastructure. Yet, only 
one of the plans--drinking water and water treatment--specifically 
included all three categories of assets. For example, because the 
communications sector limited its definition of assets to networks, 
systems, and functions, it did not, as required by DHS's plan guidance, 
include human assets in its existing security projects and the gaps it 
needs to fill related to these assets to support the sector's goals. In 
addition, the national monuments and icons plan defined the sector as 
consisting of physical structures with minimal cyber and 
telecommunications assets because these assets are not sufficiently 
critical that damaging or destroying them would interfere with the 
continued operation of the physical assets. In contrast, the energy 
sector placed a greater emphasis on cyber attributes because it heavily 
depends on these cyber assets to monitor and control its energy 
systems. DHS officials also attributed the difference in the extent to 
which the plans addressed required elements to the manner in which the 
sectors define their assets and functions. 

The plans, according to DHS's Office of Infrastructure Protection 
officials, are a first step in developing future protective measures. 
In addition, these officials said that the plans should not be 
considered to be reports of actual implementation of such measures. 
Given the disparity in the plans, it is unclear the extent to which DHS 
will be able to use them to identify gaps and interdependencies across 
the sectors in order to plan future protective measures. It is also 
unclear, from reviewing the plans, how far along each sector actually 
is in identifying assets, setting priorities, and protecting key 
assets. DHS officials said that to make this determination, they will 
need to review the sectors' annual progress reports, due this month, 
that are to provide additional information on plan implementation as 
well as identify sector priorities. 

Council Representatives Disagreed on the Value of the Plans and the 
Review Process: 

Representatives of 10 of 32 councils said the plans were valuable 
because they gave their sectors a common language and framework to 
bring the disparate members of the sector together to better 
collaborate as they move forward with protection efforts. For example, 
the government facilities council representative said that the plan was 
useful because relationships across the sector were established during 
its development that have resulted in bringing previously disjointed 
security efforts together in a coordinated way. The banking and finance 
sector's coordinating council representative said that the plan was a 
helpful way of documenting the history, the present state, and the 
future of the sector in a way that had not been done before and that 
the plan will be a working document to guide the sector in coordinating 
efforts. Similarly, an energy sector representative said that the plan 
provides a common format so that all participants can speak a common 
language, thus enabling them to better collaborate on the overall 
security of the sector. The representative also said that the plan 
brought the issue of interdependencies between the energy sector and 
other sectors to light and provided a forum for the various sectors to 
collaborate. Officials from DHS's Office of Infrastructure Protection 
agreed that the main benefit of these plans was that the process of 
developing them helped the sectors to establish relationships between 
the private sector and the government and among private sector 
stakeholders that are key to the success of protection efforts. 

However, representatives of 8 of the 32 councils said the plans were 
not useful to their sectors because (1) the plans did not represent a 
true partnership between the federal and private sectors or were not 
meaningful to all the industries represented by the sector or (2) the 
sector had already taken significant protection actions, thus, 
developing the plan did not add value. The remaining council 
representatives did not offer views on this issue. Sector 
representatives for three transportation modes--rail, maritime, and 
aviation--reported that their sector's plan was written by the 
government and that the private sector did not participate fully in the 
development of the plan or the review process. As a result, the 
representatives did not believe that the plan was of value to the 
transportation sector as a whole because it does not represent the 
interests of the private sector. Similarly, agriculture and food 
representatives said writing the plan proved to be difficult because of 
the sector's diversity and size--more than 2,000,000 farms, one million 
restaurants, and 150,000 meat processing plants. They said that one of 
the sector's biggest challenges was developing a meaningful document 
that could be used by all of the industries represented. As a result of 
these challenges, the sector submitted two plans in December 2006 that 
represented a best effort at the time, but the sector council said it 
intends to use the remainder of the 2007 calendar year to create a 
single plan that better represents the sector. In contrast, the 
coordinating councils representative for the nuclear reactors, 
materials, and waste sector said that because the sector's security has 
been robust for a long time, the plan only casts the security of the 
sector in a different light, and the drinking water and water treatment 
systems sector said that the plan is a "snapshot in time" document for 
a sector that already has a 30-year history of protection, and thus the 
plan did not provide added value for the sector. The Officials at DHS's 
Office of Infrastructure Protection acknowledged that these sectors 
have a long history of working together and in some cases have been 
doing similar planning efforts. However, the officials said that the 
effort was of value to the government because it now has plans for all 
17 sectors and it can begin to use the plans to address the NIPP risk 
management framework. 

Representatives of 11 of 32 councils said the review process associated 
with the plans was lengthy. They commented that they had submitted 
their plans in advance of the December 31, 2006, deadline, but had to 
wait 5 months for the plan to be approved. Eight of them also commented 
that while they were required to respond within several days to 
comments from DHS on the draft plans, they had to wait relatively much 
longer during the continuing review process for the next iteration of 
the draft. For example, a drinking water and water treatment sector 
representative said that the time the sector had to incorporate DHS's 
comments into a draft of the plan was too short--a few days--and this 
led the sector to question whether its members were valued partners to 
DHS. DHS Infrastructure Protection officials agreed that the review 
process had been lengthy and that the comment periods given to sector 
officials were too short. DHS officials said this occurred because of 
the volume of work DHS had to undertake and because some of the sector- 
specific agencies were still learning to operate effectively with the 
private sector under a partnership model in which the private sector is 
an equal partner. The officials said that they plan to refine the 
process as the sector-specific agencies gain more experience working 
with the private sector. 

Conversely, representatives from eight of 32 councils said the review 
process for the plans worked well, and five of these council 
representatives were complimentary of the support they received from 
DHS. The remaining council representatives did not offer views on this 
topic. For example, an information technology (IT) sector coordinating 
council representative said that the review and feedback process on 
their plan worked well and that the Office of Infrastructure Protection 
has helped tremendously in bringing the plans to fruition. However, 
sector coordinating council representatives for six sectors also voiced 
concern that the trusted relationships established between the sectors 
and DHS might not continue if there were additional turnover in DHS, as 
has occurred in the past. For example, the representative of one 
council said they had established productive working relationships with 
officials in the Offices of Infrastructure Protection and Cyber 
Security and Communications, but were concerned that these 
relationships were dependent on the individuals in these positions and 
that the relationships may not continue without the same individuals in 
charge at DHS. As we have reported in the past, developing trusted 
partnerships between the federal government and the private sector is 
critical to ensure the protection of critical infrastructure.[Footnote 
14] 

Long-standing Relationships Continue to Facilitate Councils, but Some 
Council Representatives Reported Information-Sharing Challenges: 

Nine of 32 sector representatives said that their preexisting 
relationships with stakeholders helped in establishing and maintaining 
their sector councils, and two noted that establishing the councils had 
improved relationships. Such participation is critical to well- 
functioning councils. For example, representatives from the dams, 
energy, and banking and finance sector, among others, said that 
existing relationships continue to help in maintaining their councils. 
In addition, the defense industrial base representatives said the 
organizational infrastructure provided by the sector councils is 
valuable because it allows for collaboration. The representatives from 
the national monuments and icons sector said that establishing the 
government sector council has facilitated communication within the 
sector. We also reported previously that long-standing relationships 
were a facilitating factor in council formation and that 10 sectors had 
formed either a government council or sector council that addressed 
critical infrastructure protection issues prior to DHS's development of 
the NIPP.[Footnote 15] As a result, these 10 sectors were more easily 
able to establish government coordinating councils and sector 
coordinating councils under the NIPP model. Several councils also noted 
that the Critical Infrastructure Partnership Advisory Council (CIPAC), 
created by DHS in March 2006 to facilitate communication and 
information sharing between the government and the private sector, has 
helped facilitate collaboration because it allows the government and 
industry to interact without being open to public scrutiny under the 
Federal Advisory Committee Act.[Footnote 16] This is important because 
previously, meetings between the private sector and the government had 
to be open to the public, hampering the private sector's willingness to 
share information. 

Conversely, seven sector council representatives reported difficulty in 
achieving and maintaining sector council membership, thus limiting the 
ability of the councils to effectively represent the sector. For 
example, the public health and health care sector representative said 
that getting the numerous sector members to participate is a challenge, 
and the government representative noted that because of this, the first 
step in implementing the sector-specific plan is to increase awareness 
about the effort among sector members to encourage participation. 
Similarly, due to the size of the commercial facilities sector, 
participation, while critical, varies among its industries, according 
to the government council representative. Meanwhile, the banking and 
finance sector representatives said that the time commitment for 
private sector members and council leaders makes participation 
difficult for smaller stakeholders, but getting them involved is 
critical to an effective partnership. Likewise, the IT sector 
representatives said engaging some government members in joint council 
meetings is a continuing challenge because of the members' competing 
responsibilities. Without such involvement, officials said, it is 
difficult to convince the private sector representatives of the value 
of spending their time participating on the council. 

Additionally, obtaining state and local government participation in 
government sector councils remains a challenge for five sectors. 
Achieving such participation is critical because these officials are 
often the first responders in case of an incident. Several government 
council representatives said that a lack of funding for representatives 
from these entities to travel to key meetings has limited state and 
local government participation. Others stated that determining which 
officials to include was a challenge because of the sheer volume of 
state and local stakeholders. DHS Infrastructure Protection officials 
said that the agency is trying to address this issue by providing 
funding for state and local participation in quarterly sector council 
meetings and has created a State, Local and Tribal and Territorial 
Government Coordinating Council (SLTTGCC)--composed of state, local, 
tribal, and territorial homeland security advisers--that serves as a 
forum for coordination across these jurisdictions on protection 
guidance, strategies, and programs. 

Eleven of the 32 council representatives reported continuing challenges 
with sharing information between the federal government and the private 
sector. For example, six council representatives expressed concerns 
about the viability of two of DHS's main information-sharing tools--the 
Homeland Security Information Network (HSIN) or the Protected Critical 
Infrastructure Information (PCII) program. We reported in April 2007 
that the HSIN system was built without appropriate coordination with 
other information-sharing initiatives.[Footnote 17] In addition, in a 
strategic review of HSIN, DHS reported in April 2007 that it has not 
clearly defined the purpose and scope of HSIN and that HSIN has been 
developed without sufficient planning and program management. According 
to DHS Infrastructure Protection officials, although they encouraged 
the sectors to use HSIN, the system does not provide the capabilities 
that were promised, including providing the level of security expected 
by some sectors. As a result, they said the Office of Infrastructure 
Protection is exploring an alternative that would better meet the needs 
of the sectors. In addition, three council representatives expressed 
concerns about whether information shared under the PCII program would 
be protected. Although this program was specifically designed to 
establish procedures for the receipt, care, and storage of critical 
infrastructure information submitted voluntarily to the government, 
representatives said potential submitters continue to fear that the 
information could be inadequately protected, used for future legal or 
regulatory action, or inadvertently released. 

In April 2006, we reported that DHS faced challenges implementing the 
program, including being able to assure the private sector that 
submitted information will be protected and specifying who will be 
authorized to have access to the information, as well as to demonstrate 
to the critical infrastructure owners the benefits of sharing the 
information to encourage program participation.[Footnote 18] We 
recommended, among other things, that DHS better (1) define its 
critical-infrastructure information needs and (2) explain how this 
information will be used to attract more users. DHS concurred with our 
recommendations. In September 2006 DHS issued a final rule that 
established procedures governing the receipt, validation, handling, 
storage, marking, and use of critical infrastructure information 
voluntarily submitted to DHS. DHS is in the process of implementing our 
additional recommendations. 

Agency Comments: 

In commenting on a draft of this statement, DHS said that it could not 
provide formal agency comments in the time allowed. However, DHS 
provided technical comments that have been incorporated, as 
appropriate. 

Concluding Observations: 

To date, DHS has issued a national plan aimed at providing a consistent 
approach to critical infrastructure protection, ensured that all 17 
sectors have organized to collaborate on protection efforts, and worked 
with government and private sector partners to complete all 17 sector- 
specific plans. Nevertheless, our work has shown that sectors vary in 
terms of how complete and comprehensive their plans are. Furthermore, 
DHS recognizes that the sectors, their councils, and their plans must 
continue to evolve. As they do, and as the plans are updated and annual 
implementation reports are provided that begin to show the level of 
protection achieved, it will be important that the plans and reports 
add value, both to the sectors themselves and to the government as a 
whole. This is critical because DHS is dependent on these plans and 
reports to meet its mandate to evaluate whether gaps exist in the 
protection of the nation's most critical infrastructure and key 
resources and, if gaps exist, to work with the sectors to address them. 
Likewise, DHS must depend on the private sector to voluntarily put 
protective measures in place for many assets. It will also be important 
that sector councils have representative members and that the sector- 
specific agencies have buy-in from these members on protection plans 
and implementation steps. One step DHS could take to implement our past 
recommendations to strengthen the sharing of information is for the 
PCII program to better define its critical infrastructure information 
needs and better explain how this information will be used to build the 
private sector's trust and attract more users. As we have previously 
reported, such sharing of information and building of trusted 
relationships are crucial to the protection of the nation's critical 
infrastructure. 

We are sending copies of this report to selected congressional 
committees with responsibilities for critical infrastructure protection 
issues; the Secretaries of Agriculture, Defense, Energy, Health and 
Human Services, Homeland Security, the Interior, and the Treasury; and 
the Administrator of the Environmental Protection Agency. We are also 
making copies available to others upon request. This report will be 
available at no charge on GAO's Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please 
contact Eileen R. Larence at (202) 512-8777 or at larence@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report are listed in enclosure II. 

Signed by: 

Eileen R. Larence: 
Director, Homeland Security and Justice Issues: 

Enclosures: 

[End of section] 

Enclosure I: Criteria Used to Determine Completeness of Sector Specific 
Plans: 

We assessed the sector specific plans (SSPs) using 8 criteria, 
consisting of 40 key information requirements. We extracted this 
information from the requirements included in the NIPP as well as on 
the detailed sector-specific plan guidance issued by DHS. Each 
criterion reflects a component DHS required for the completion of the 
SSP. The 8 criteria we used are listed below along with the 
corresponding 40 key information requirements. 

Section 1: Sector Profile and Goals: 

1. Did the sector include physical and human assets as part of its 
sector profile?[Footnote 19] 

2. Does the SSP identify any regulations or key authorities relevant to 
the sector that affect physical and human assets and protection? 

3. Does the SSP show the relationships between the sector specific 
agency and the private sector, other federal departments and agencies, 
and state and local agencies that are either owner/operators of assets 
or provide a supporting role to securing key resources? 

4. Does the SSP contain sector-specific goals? 

5. Does the SSP communicate the value of the plan to the private 
sector, other owners, and operators? 

Section 2: Identify Assets, Systems, Networks, and Functions: 

6. Does the SSP include a process for identifying the sector's assets 
and functions, both now and in the future? 

7. Does the SSP include a process to identify physical and human asset 
dependencies and interdependencies? 

8. Does the SSP describe the criteria being used to determine which 
assets, systems, and networks are and are not of potential concern? 

9. Does the SSP describe how the infrastructure information being 
collected will be verified for accuracy and completeness? 

Section 3: Assess Risks: 

10. Does the SSP discuss the risk assessment process, including whether 
the sector is mandated by regulation or are primarily voluntary in 
nature. 

11. Does the SSP address whether a screening process (process to 
determine whether a full assessment is required) for assets would be 
beneficial for the sector, and if so, does it discuss the methodologies 
or tools that would be used to do so? 

12. Does the SSP identify how potential consequences of incidents, 
including worst case scenarios, would be assessed? 

13. Does the SSP describe the relevant processes and methodologies used 
to perform vulnerability assessments? 

14. Does the SSP describe any threat analyses that the sector conducts? 

15. Does the SSP describe any incentives used to encourage voluntary 
performance of risk assessments? 

Section 4: Prioritize Infrastructure: 

16. Does the SSP identify the party responsible for conducting a risk- 
based prioritizing of the assets? 

17. Does the SSP describe the process, current criteria, and frequency 
for prioritizing sector assets? 

18. Does the SSP provide a common methodology for comparing both 
physical and human assets when prioritizing a sector's infrastructure? 

Section 5: Develop and Implement Protective Programs: 

19. Does the SSP describe the process that the SSA will use to work 
with asset owners to develop effective long-term protective plans for 
the sector's assets? 

20. Does the SSP identify key protective programs (and their role) in 
the sector's overall risk management approach? 

21. Does the SSP describe the process used to identify and validate 
specific program needs? 

22. Does the SSP include the minimum requirements necessary for the 
sector to prevent, protect, respond to, and recover from an attack? 

23. Does the SSP address implementation and maintenance of protective 
programs for assets once they are prioritized? 

24. Does the SSP address how the performance of protective programs is 
monitored by the sector-specific agencies and security partners to 
determine their effectiveness? 

Section 6: Measure Progress: 

25. Does the SSP explain how the SSA will collect, verify and report 
the information necessary to measure progress in critical 
infrastructure/ key resources protection? 

26. Does the SSP describe how the SSA will report the results of its 
performance assessments to the Secretary of Homeland Security? 

27. Does the SSP call for the development and use of metrics that will 
allow the SSA to measure the results of activities related to assets? 

28. Does the SPP describe how performance metrics will be used to guide 
future decisions on projects? 

29. Does the SSP list relevant sector-level implementation actions that 
the SSA and its security partners deem appropriate? 

Section 7: Research and Development for Critical Infrastructure/Key 
Resources Protection: 

30. Does the SSP describe how technology development is related to the 
sector's goals? 

31. Does the SSP identify those sector capability requirements that can 
be supported by technology development? 

32. Does the SSP describe the process used to identify physical and 
human sector-related research requirements? 

33. Does the SSP identify existing security projects and the gaps it 
needs to fill to support the sector's goals? 

34. Does the SSP identify which sector governance structures will be 
responsible for R&D? 

35. Does the SSP describe the criteria that are used to select new and 
existing initiatives? 

Section 8: Manage and Coordinate SSA Responsibilities: 

36. Does the SSP describe how the SSA intends to staff and manage its 
NIPP responsibilities? (e.g., creation of a program management office): 

37. Does the SSP describe the processes and responsibilities of 
updating, reporting, budgeting, and training? 

38. Does the SSP describe the sector's coordinating mechanisms and 
structures? 

39. Does the SSP describe the process for developing the sector-
specific investment priorities and requirements for critical 
infrastructure/key resource protection? 

40. Does the SSP describe the process for information sharing and 
protection? 

[End of section] 

Enclosure II: GAO Contact and Staff Acknowledgments: 

GAO Contact: Eileen R. Larence (202) 512-8777: 

Staff Acknowledgments: In addition to the contact named above, Susan 
Quinlan, Assistant Director; R. E. Canjar; Landis Lindsey; E. Jerry 
Seigler; and Edith Sohna made key contributions to this report. 

(440592): 

FOOTNOTES 

[1] "Critical infrastructure" are systems and assets, whether physical 
or virtual, so vital to the United States that their incapacity or 
destruction would have a debilitating impact on national security, 
national economic security, national public health or safety, or any 
combination of those matters. Key resources are publicly or privately 
controlled resources essential to minimal operations of the economy or 
government, including individual targets whose destruction would not 
endanger vital systems but could create a local disaster or profoundly 
damage the nation's morale or confidence. For purposes of this report, 
we will use the term "critical infrastructure" to also include key 
resources. 

[2] See Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

[3] These infrastructure sectors include agriculture and food; banking 
and finance; chemical; commercial facilities; commercial nuclear 
reactors, materials, and waste; communications; dams; defense 
industrial base; drinking water and water treatment systems; emergency 
services; energy; government facilities; information technology; 
national monuments and icons; postal and shipping; public health and 
health care; and transportation systems. 

[4] The government facilities and the national monuments and icons 
sectors do not have sector councils because they do not have private 
sector counterparts. 

[5] We selected the nine plans to obtain a range of plans based on 
sector characteristics, such as the maturity--sectors with pre-existing 
relationships and a history of working together--and diversity of the 
sector. The plans we reviewed were banking and finance, communications, 
defense industrial base, energy, public health and healthcare, 
information technology (IT), national monuments and icons, 
transportation systems, and drinking water and water treatment systems. 
According to DHS officials, differences between these draft plans and 
the final plans issued on May 21, 2007, were insignificant. 

[6] DHS is the sector-specific agency for 10 sectors: information 
technology; communications; transportation systems; chemical; emergency 
services; commercial nuclear reactors, material, and waste; postal and 
shipping; dams; government facilities; and commercial facilities. 

[7] See enclosure I for the required elements on which we reviewed the 
plans. 

[8] In the context of the NIPP, a "system" is a collection of assets, 
resources, or elements that perform a process that provides 
infrastructure services to the nation. A "function" is defined as the 
service, process, capability, or operation performed by specific 
infrastructure assets, systems, or networks. 

[9] GAO, Critical Infrastructure Protection: Progress Coordinating 
Government and Private Sector Efforts Varies by Sectors' 
Characteristics, GAO-07-39 (Washington, D.C.: Oct. 16, 2006). 

[10] GAO, Information Technology: Numerous Federal Networks Used to 
Support Homeland Security Need to Be Better Coordinated with Key State 
and Local Information-Sharing Initiatives, GAO-07-455 (Washington, 
D.C.: Apr. 16, 2007). 

[11] GAO, Information Sharing: DHS Should Take Steps to Encourage More 
Widespread Use of Its Program to Protect and Share Critical 
Infrastructure Information, GAO-06-383 (Washington, D.C.: Apr. 17, 
2006). 

[12] According to the NIPP, a "consequence" is the result of a 
terrorist attack or hazard that reflects the level, duration, and 
nature of the loss resulting from the incident. A "vulnerability" is a 
weakness in the design, implementation, or operation of an asset, 
system, or network that can be exploited by an adversary or disrupted 
by a natural hazard or technological failure. A "threat" is the 
intention and capability of an adversary to undertake actions that 
would be detrimental to critical infrastructure and key resources. 

[13] See enclosure I for a full list of the requirements on which we 
evaluated the plans. 

[14] GAO, Critical Infrastructure Protection: Improving Information 
Sharing with Infrastructure Sectors, GAO-04-780 (Washington, D.C.: July 
9, 2004) and Information Sharing: Practices That Can Benefit Critical 
Infrastructure Protection, GAO-02-24 (Washington, D.C.: Oct. 15, 2001). 

[15] See GAO-07-39. 

[16] The Federal Advisory Committee Act (codified at 5 U.S.C. app. 2) 
was enacted, in part, to control the advisory committee process and to 
open to public scrutiny the manner in which government agencies obtain 
advice from private individuals and groups. See 648 F. Supp. 1353, 1358-
59 (D.D.C. 1986). Section 871 of the Homeland Security Act authorized a 
process under which the Secretary could exempt an advisory committee 
from the Federal Advisory Committee Act. See Pub. L. No. 107- 296,  
871, 116 Stat. 2135, 2243. 

[17] See GAO-07-455. 

[18] See GAO-06-383. 

[19] A companion engagement assessed the plans for inclusion of cyber 
assets. 

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