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United States Government Accountability Office: 
Washington, DC 20548: 

April 2, 2008: 

The Honorable Solomon P. Ortiz:
Chairman:
The Honorable J. Randy Forbes:
Ranking Member:
Subcommittee on Readiness:
Committee on Armed Services:
House of Representatives: 

The Honorable William T. Akin:
House of Representatives: 

Subject: Defense Critical Infrastructure: DOD's Risk Analysis of Its 
Critical Infrastructure Omits Highly Sensitive Assets: 

The Department of Defense (DOD) relies on a global network of critical 
physical and cyber infrastructure to project, support, and sustain its 
forces and operations worldwide. The incapacitation, exploitation, or 
destruction of one or more of its assets would seriously damage DOD's 
ability to carry out its core missions. To identify and help assure the 
availability of this mission-critical infrastructure, in August 2005, 
DOD established the Defense Critical Infrastructure Program (DCIP), 
assigning overall responsibility for the program to the Assistant 
Secretary of Defense for Homeland Defense and Americas' Security 
Affairs (ASD[HD&ASA]).[Footnote 1] 

Since 2006, ASD(HD&ASA) has collaborated with the Joint Staff to 
compile a list of all DOD-and non-DOD-owned infrastructure essential to 
accomplish the National Defense Strategy.[Footnote 2] Each critical 
asset on the list must undergo a vulnerability assessment, which 
identifies weaknesses in relation to potential threats and suggests 
options to address those weaknesses. 

Data and material designated as Sensitive Compartmented Information 
(SCI)[Footnote 3] or associated with Special Access Programs 
(SAP)[Footnote 4] are among the nation's most valued and closely 
guarded assets, and DOD faces inherent challenges in incorporating them 
into DCIP. The number of individuals authorized to access SCI and SAPs 
is a relatively small subset of those authorized to access collateral-
level classified information--that is, Confidential, Secret, or Top 
Secret information. The relationship between collateral, SCI, and SAP 
designations is depicted in figure 1. 

Figure 1: Relationship between Collateral, SCI, and SAP Designations: 

[See PDF for image] 

This figure is an illustration of the relationship between Collateral, 
SCI, and SAP designations, utilizing a series of concentric half-
circles. The core of the concentric half-circles is designated as 
confidential. The next half-circle is designated secret, and the outer 
half-circle is designated top secret. Within each designation there are 
collateral and non-collateral designations, as well. Both SAP's and SCI 
are illustrated as non-collateral, secret and top secret. 

Source: GAO analysis. 

Note: The areas shown here represent categories of national security 
information. All classified information is Confidential, Secret, or Top 
Secret. Information classified at these levels but not subject to any 
additional safeguarding and access requirements is collateral 
information. Some information that is classified Secret or Top Secret 
also falls under an SCI or SAP designation; that information then 
becomes non-collateral. The relative size of each area is illustrative 
only. 

[End of figure] 

You requested that we review a number of issues related to defense 
critical infrastructure. To date, we have issued two reports in 
response to that request. Our first report[Footnote 5] examined the 
extent to which DOD had developed a comprehensive management plan for 
DCIP and had identified, prioritized, and assessed defense critical 
infrastructure. Our second report[Footnote 6] examined DOD's efforts to 
implement a risk management approach for critical assets in the Defense 
Industrial Base Defense Sector. As agreed with your offices, we plan to 
issue reports later this year that examine actions DOD has taken to 
assure the availability of its critical infrastructure in the 
Transportation; Space; Intelligence, Surveillance, and Reconnaissance; 
Global Information Grid; and Public Works Defense Sectors. 

As part of our ongoing work on DOD's critical infrastructure protection 
efforts, this report focuses on challenges DOD faces in incorporating 
critical SCI and SAP assets into DCIP. Specifically, this report 
evaluates the extent to which DOD is (1) identifying and prioritizing 
critical SCI and SAP assets in DCIP and (2) assessing critical SCI and 
SAP assets for vulnerabilities in a comprehensive manner consistent 
with that used by DCIP for collateral-level assets. 

To determine the extent to which DOD is identifying and prioritizing 
critical SCI and SAP assets in DCIP and assessing them for 
vulnerabilities using DCIP criteria, we reviewed guidance, critical 
asset lists, planning documents, and other relevant documentation, and 
we interviewed officials from the following DOD organizations: the 
Office of the ASD(HD&ASA), the Joint Staff Deputy Directorate for 
Antiterrorism and Homeland Defense, the Office of the Under Secretary 
of Defense for Intelligence, the DOD Special Access Program Central 
Office, the Defense Intelligence Agency, the Defense Contract 
Management Agency, and the nine geographic and functional combatant 
commands.[Footnote 7] We conducted this performance audit from 
September 2007 through February 2008 in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Results in Brief: 

Although DOD Directive 3020.40 calls for the identification and 
prioritization of all defense critical infrastructure, DOD has not 
taken adequate steps to ensure that highly sensitive critical assets 
associated with SCI and SAPs are accounted for, either through DCIP or 
a comparable process. The Joint Staff has tasked DOD organizations to 
submit lists of critical assets classified at the collateral level 
only--in part, to facilitate vetting and sharing critical asset lists 
across the department. As a consequence, some DOD organizations have 
omitted SCI and SAP assets from their submissions. For example, the 
Defense Intelligence Agency--the DOD lead agent for the Intelligence, 
Surveillance, and Reconnaissance Defense Sector--has not forwarded to 
the Joint Staff a list of over 80 assets it has identified as critical, 
because neither the Joint Staff nor ASD(HD&ASA) has fully incorporated 
provisions for including SCI data into DCIP. Although ASD(HD&ASA) and 
Joint Staff officials have initiated some actions to increase their 
access to SCI--for example, by requesting additional SCI clearances for 
staff and pursuing means to store and share SCI data--these actions are 
not likely to resolve information-sharing problems across the 
department because many officials in other DCIP organizations may still 
lack access to SCI. Additionally, DOD officials told us that stringent 
"need to know" requirements for SAP information will likely prevent 
ASD(HD&ASA) and other DCIP officials from obtaining greater access to 
information on SAP assets in the foreseeable future. By excluding SCI 
and SAP infrastructure, DOD's processes for soliciting critical asset 
information do not result in consistent and comprehensive 
identification and prioritization of all critical infrastructure. Yet 
ASD(HD&ASA) has not pursued alternative approaches, such as partnering 
with other DOD organizations that have greater SCI and SAP access, to 
develop parallel identification and prioritization processes. Unless 
critical SCI and SAP assets are identified and prioritized, DOD will 
lack sufficient information to assure the availability of the 
department's most critical assets. 

DOD guidance requires all critical infrastructure to be assessed for 
vulnerabilities using DCIP standards and benchmarks, but because SCI 
and SAP assets have not been reported as critical, they do not receive 
these assessments. Should any unreported critical SCI assets be 
reported under DCIP, the Defense Threat Reduction Agency has personnel 
who possess SCI clearances, and therefore could assess those assets. 
However, because of the greater access restrictions placed on SAP data, 
Defense Threat Reduction Agency officials are unlikely to gain access 
to the highly sensitive information needed to assess SAP assets. 
Separately from DCIP, the Defense Intelligence Agency assesses the 
vulnerabilities of SCI and SAP assets. However, those assessments are 
intended to support information and physical security rather than 
mission assurance. Accordingly, they do not include certain key 
elements of the assessments administered under DCIP, such as a mission-
based orientation and an all-hazards analysis. The guidance the Defense 
Intelligence Agency uses to assess SCI and SAP assets focuses on the 
need to secure information from unauthorized disclosure rather than on 
the need to maintain continuity of mission-essential functions, and it 
emphasizes human threats, such as terrorism, rather than all potential 
hazards. Because of these fundamental differences, the Defense 
Intelligence Agency's assessments of SCI and SAP assets cannot 
substitute for the mission-based, all-hazards vulnerability 
assessments required by DCIP. As a result, DOD lacks a consistent 
process for assessing its collateral and its more sensitive critical 
assets. Without using a consistent vulnerability assessment process for 
all its critical assets, including SCI and SAP assets, DOD cannot 
effectively analyze the comparative value of risk reduction actions. 

We are recommending that ASD(HD&ASA) develop a process to identify, 
prioritize, and assess critical SCI and SAP assets in a manner 
consistent with DCIP, and amend its DCIP security classification 
guidance to specifically address how SCI and SAP critical 
infrastructure information should be treated. 

In written comments on a draft of this report, DOD generally agreed 
with our recommendations. DOD's comments are discussed in more detail 
at the end of this report and are reproduced in full in enclosure I. 
DOD also provided us with technical comments, which have been 
incorporated where appropriate. 

Background: 

Recognizing that it is neither practical nor feasible to protect its 
entire infrastructure against every possible threat, DOD is pursuing a 
risk management approach to help direct limited resources to higher-
priority, higher-risk assets. DOD's risk management approach is based 
on assessing criticality, threat, vulnerability, and the ability to 
respond to incidents. Criticality assessments evaluate and prioritize 
assets on the basis of their importance to mission success. Threat 
assessments identify and evaluate potential threats to critical assets 
before they materialize, on the basis of capabilities, intentions, and 
past events. Vulnerability assessments analyze weaknesses in relation 
to identified threats and suggest options to address those weaknesses. 
DOD's risk management approach also includes an assessment of the 
ability to respond to, and recover from, an incident. 

In response to the guidance contained in Homeland Security Presidential 
Directive 7,[Footnote 8] DOD formalized its critical infrastructure 
efforts on August 19, 2005, by issuing DOD Directive 3020.40, Defense 
Critical Infrastructure Program (DCIP), which established the program 
and assigned overall responsibility to ASD(HD&ASA). DOD Directive 
3020.40 requires, among other things, that ASD(HD&ASA) develop and 
ensure implementation of DCIP policy and program guidance for the 
identification, prioritization, and protection of defense critical 
infrastructure. 

Pursuant to DOD Directive 3020.40, DOD has defined 10 virtual, 
functionally-based defense sectors comprising the critical 
infrastructure that crosses traditional organizational boundaries, and 
it has appointed a lead agent for each sector. The 10 defense sectors 
and their corresponding lead agents are listed in table 1. 

Table 1: Defense Infrastructure Sectors and Corresponding Lead Agents: 

Defense infrastructure sector: Defense Industrial Base; 
Defense infrastructure sector lead agent: Defense Contract Management 
Agency. 

Defense infrastructure sector: Financial Services; 
Defense infrastructure sector lead agent: Defense Finance and 
Accounting Service. 

Defense infrastructure sector: Global Information Grid; 
Defense infrastructure sector lead agent: Defense Information Systems 
Agency. 

Defense infrastructure sector: Health Affairs; 
Defense infrastructure sector lead agent: Assistant Secretary of 
Defense for Health Affairs. 

Defense infrastructure sector: Intelligence, Surveillance, and 
Reconnaissance; 
Defense infrastructure sector lead agent: Defense Intelligence Agency. 

Defense infrastructure sector: Logistics; 
Defense infrastructure sector lead agent: Defense Logistics Agency. 

Defense infrastructure sector: Personnel; 
Defense infrastructure sector lead agent: Under Secretary of Defense 
for Personnel and Readiness. 

Defense infrastructure sector: Public Works; 
Defense infrastructure sector lead agent: U.S. Army Corps of Engineers. 

Defense infrastructure sector: Space; 
Defense infrastructure sector lead agent: U.S. Strategic Command. 

Defense infrastructure sector: Transportation; 
Defense infrastructure sector lead agent: U.S. Transportation Command. 

Source: GAO analysis of DOD data. 

[End of table] 

ASD(HD&ASA) and the Joint Staff have tasked the combatant commands, 
military services, field activities, defense agencies, and defense 
infrastructure sector lead agents with nominating infrastructure 
necessary to accomplish the goals specified in the National Defense 
Strategy. The combatant commands, in collaboration with the Joint 
Staff, identify and prioritize DOD missions that are the basis for 
determining infrastructure criticality. The military services, as the 
principal owners of DOD infrastructure, identify and link 
infrastructure to specific combatant command mission requirements. 
Defense infrastructure sector lead agents address the interdependencies 
among infrastructure that cross organizational boundaries, and evaluate 
the cascading effects of degraded or lost infrastructure on other 
infrastructure assets. Assets nominated by the combatant commands and 
services have been assembled into a consolidated draft critical asset 
list, which ASD(HD&ASA) will use as the basis for a final list. The 
Joint Staff plans to send the latest iteration of the draft list to 
ASD(HD&ASA) in April 2008. ASD(HD&ASA) officials told us they expect to 
approve and issue a final critical asset list within 90 days of 
receiving a final draft list from the Joint Staff, which will include 
assets nominated by the defense infrastructure sector lead agents. 

According to DCIP guidance,[Footnote 9] all defense critical assets 
must undergo vulnerability assessments. These assessments, performed 
primarily by the Defense Threat Reduction Agency or by asset owners 
themselves, follow a set of standards and benchmarks developed and 
maintained by ASD(HD&ASA).[Footnote 10] DCIP assessments use a mission-
assurance approach; that is, they discern what weaknesses, if any, 
threaten an asset's continued availability to support its associated 
defense missions. This mission-based analysis, according to DCIP 
standards and benchmarks,[Footnote 11] requires assessment teams to 
consider an exhaustive set of potential hazards, including chemical, 
biological, radiological, nuclear, and explosive events; 
electromagnetic pulse; sabotage; projectile impact; cyber threats; 
arson; earthquakes, hurricanes, fire, and other natural disasters or 
weather events; collocated construction or digging activities; work 
stoppage or strike; and wildlife activity. DCIP's mission-assurance, 
all-hazards approach mirrors risk management strategies developed by 
the Department of Homeland Security, with the intention of providing a 
sound and systematic basis for deciding whether and how to accept, 
reduce, or offset risk to DOD's most mission-critical infrastructure. 

DOD Has Not Included SCI and SAP Assets in Its Identification and 
Prioritization of Critical Infrastructure: 

Although DOD Directive 3020.40 calls for the identification and 
prioritization of all defense critical infrastructure and the 
development of policies that promote information sharing while properly 
safeguarding sensitive data, DOD has not taken adequate steps to 
account for critical infrastructure associated with SCI and SAPs, 
either through DCIP or an alternative approach. DOD organizations have 
submitted critical assets at the collateral level only, because the 
instructions they received did not address SCI or SAP assets. Moreover, 
key ASD(HD&ASA) officials involved with DCIP are not authorized to 
access SCI and SAP data, even if such data were submitted to them. 

DOD Organizations Have Not Reported SCI and SAP Critical Assets: 

The Joint Staff, in preparing the critical asset list on behalf of 
ASD(HD&ASA), gave written instructions to DOD organizations on how to 
submit critical assets at the Secret or Top Secret levels; however, 
these instructions did not address how to submit critical SCI or SAP 
assets. The DCIP Security Classification Guide[Footnote 12]--which 
describes what information related to critical infrastructure meets the 
standards of Confidential, Secret, or Top Secret at the collateral 
level--also does not specifically address SCI or SAP data related to 
critical infrastructure. The Joint Staff instructions and the guide do 
not rule out the designation of some critical asset information as SCI 
or SAP, but officials from two DOD organizations told us that the lack 
of explicit guidance on how to treat SCI and SAP data caused them not 
to fully report their critical assets. The Defense Intelligence Agency, 
the lead agent for the Intelligence, Surveillance, and Reconnaissance 
Defense Sector, has compiled a list of over 80 assets nominated by both 
the Defense Intelligence Agency and by the National Security Agency, 
the National Reconnaissance Office, the National Geospatial-
Intelligence Agency, the military service intelligence activities, and 
the combatant command intelligence staffs. Defense Intelligence Agency 
officials told us that they have not forwarded the list to the Joint 
Staff because provisions for including SCI data have not been fully 
incorporated into DCIP. Similarly, officials at the Defense Contract 
Management Agency, the lead agent for the Defense Industrial Base 
Defense Sector, told us they have not reported any critical assets 
associated with SAPs because they believe that DCIP policies do not 
require them to do so. DCIP policies make no such exception for SAP 
infrastructure, but the lack of explicit guidance concerning SCI and 
SAPs has led DOD organizations not to report some SCI and SAP assets as 
critical. 

In further explaining why the DOD critical asset list has been kept at 
the collateral level, Joint Staff and ASD(HD&ASA) officials stated that 
highly classified information would be difficult to share among all 
relevant DCIP stakeholders because of the limited number of individuals 
who have access to SCI and SAPs. The stringent access controls on SCI 
and SAP information would significantly restrict ASD(HD&ASA)'s ability 
to distribute among DCIP organizations any critical asset list that 
includes SCI or SAP infrastructure. Nevertheless, until DOD develops 
the means to identify and prioritize critical SCI and SAP assets, it 
cannot assure the availability of all critical defense infrastructure 
in a consistent and comprehensive way. 

During the course of our review, the Joint Staff issued new 
instructions to DOD organizations, requesting them to submit their 
lists of critical SCI assets. Joint Staff officials told us that they 
have had discussions with the Defense Intelligence Agency about 
obtaining its SCI-level list of critical intelligence, surveillance, 
and reconnaissance infrastructure. These actions represent important 
initial steps toward identifying and prioritizing critical SCI 
infrastructure; however, they remain in their initial phases only. 
Joint Staff officials acknowledged that DOD has not taken similar 
actions to begin accounting for SAP infrastructure. 

Key ASD(HD&ASA) Officials Are Not Authorized to Access SCI or SAP Data: 

A related barrier to including SCI and SAP assets in the DOD critical 
asset list is DCIP officials' lack of authority to access information 
pertaining to these highly sensitive programs. At the time of our 
review, key ASD(HD&ASA) personnel involved with DCIP were not 
authorized to handle SCI data. Similarly, ASD(HD&ASA) personnel had not 
been granted access to any SAPs, and did not expect to gain access in 
the foreseeable future. DOD policy[Footnote 13] imposes a stringent 
standard for meeting the "need to know" criterion: to handle SAP 
information an individual must "materially and directly contribute" to 
the individual SAP to which he or she requests access. DOD officials 
responsible for setting departmental SAP policy told us that 
ASD(HD&ASA) staff would almost certainly not qualify to access SAP 
information for the purpose of identifying and prioritizing defense 
critical infrastructure. For the same reason, according to an Air Force 
headquarters official responsible for SAPs, defense industrial base 
firms involved in SAPs would be reluctant to discuss their potential 
critical assets with the Defense Contract Management Agency or other 
DCIP officials.[Footnote 14] 

ASD(HD&ASA) officials are aware of these issues and have taken some 
steps to resolve them. They have requested SCI clearances for 
additional personnel, have identified a computer terminal belonging to 
another DOD organization that could be used to transmit and receive SCI 
data, and have requested a computer authorized to store and process SCI 
data. Once ASD(HD&ASA) is able to handle and store SCI data, it will 
have access to the Intelligence, Surveillance, and Reconnaissance 
Defense Sector's critical asset list. 

However, ASD(HD&ASA) has not taken similar actions to address its lack 
of access to SAPs. At the time of our review, ASD(HD&ASA) officials had 
limited coordination with DOD's SAP Central Office, the primary point-
of-contact on all issues involving defense SAPs, and limited 
coordination with other defense organizations to discern what amount of 
critical infrastructure might reside in those programs. DOD officials 
responsible for SAP policy told us that most defense SAPs involve 
acquisition programs. The Defense Contract Management Agency, which is 
tasked with analyzing acquisition infrastructure, has compiled a 
sector-specific list of critical assets, but its list contains no SAP 
infrastructure. Defense Contract Management Agency officials 
acknowledged the need to identify critical SAP assets, but told us they 
had no plan for doing so. 

Moreover, actions taken by ASD(HD&ASA) officials to increase their own 
SCI and SAP access will not be sufficient to address information-
sharing problems across other DOD organizations with key roles in DCIP. 
For example, draft DCIP guidance[Footnote 15] calls for the military 
services, combatant commands, field activities, defense agencies, 
defense infrastructure sector lead agents, and other DOD organizations 
to review and validate the draft critical asset list once it has been 
compiled. But DOD officials told us that many DCIP personnel at these 
organizations are unlikely to be granted SCI or SAP access, denying 
them the authorization required to validate any critical asset list 
that includes SCI or SAP infrastructure. 

Although DOD Directive 3020.40 tasks ASD(HD&ASA) with developing 
policies to promote information sharing while safeguarding sensitive 
data from disclosure, it has not pursued potential means of balancing 
these competing needs in the case of SCI and SAP infrastructure. For 
example, ASD(HD&ASA) has not explored the option of partnering with the 
Defense Intelligence Agency or the SAP Central Office to develop 
parallel identification and prioritization processes. These two 
organizations, or other DOD entities with the necessary access, could 
compile and maintain separate critical asset lists for SCI and SAP 
infrastructure, using standards consistent with those currently applied 
to collateral assets under DCIP. Such an approach could potentially 
fulfill DOD requirements for comprehensive risk management while 
respecting the extraordinary sensitivity of SCI and SAP data; to date, 
however, DOD has not taken steps to pursue either this or similar 
options. Unless DOD revises or supplements its identification and 
prioritization process to resolve information-sharing problems, the 
omission of SCI and SAP assets will continue to limit DOD's awareness 
of its critical infrastructure. 

SCI and SAP Vulnerability Assessments Are Not Consistent with Those 
Performed on Collateral-Level Assets: 

Although DOD guidance requires that all critical infrastructure be 
assessed for vulnerabilities using DCIP standards and benchmarks, SCI 
and SAP assets have not received DCIP assessments because they have not 
been reported as critical. The Defense Intelligence Agency operates a 
separate program for assessing SCI and SAP assets--critical and 
otherwise--but because its assessments are designed to focus on 
information security rather than mission assurance, they do not include 
certain key elements of those required for critical assets reported 
under DCIP. The Defense Intelligence Agency's guidelines for SCI and 
SAP assessments do not employ a mission-based analysis, nor do they 
require consideration of all potential hazards--whereas these two 
criteria are integral to the DCIP vulnerability assessments conducted 
on collateral-level assets. Should DCIP identify any of the critical 
SCI assets that are currently unidentified, the Defense Threat 
Reduction Agency would be able to assess those assets, as it has 
personnel who possess SCI clearances. However, Defense Threat Reduction 
Agency officials told us that because of the greater access 
restrictions placed on SAP data, they are unlikely to gain access to 
the highly sensitive, mission-related information needed to perform 
vulnerability assessments on SAP assets. 

SCI and SAP Vulnerability Assessments Do Not Include Key Risk 
Management Elements: 

The significant differences in vulnerability assessments performed on 
SCI and SAP assets, as compared with those performed on collateral-
level assets, impede DOD's ability to assure the availability of highly 
sensitive defense critical infrastructure. Table 2 compares DCIP 
assessment policies with those used for SCI and SAP assets. 

Table 2: Comparison of DCIP, SCI, and SAP Vulnerability Assessment 
Policies: 

Attribute: Periodic assessment is required; 
DCIP: Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Check]; 
SAP: Information and physical security assessments: [Check]. 

Attribute: Assets are prioritized according to criticality; 
DCIP: 
Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Attribute: Assessment focuses on combatant command missions; 
DCIP: 
Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Attribute: Assessment addresses all hazards; 
DCIP: Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Attribute: Assessment has departmentwide visibility; 
DCIP: Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Attribute: Assessment includes plans for redundancy; 
DCIP: Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Attribute: Risk remediation actions must be reported; 
DCIP: Mission assurance assessments: [Check]; 
SCI: Information and physical security assessments: [Empty]; 
SAP: Information and physical security assessments: [Empty]. 

Source: GAO analysis of DOD data. 

[End of table] 

While DCIP risk management policies call for a mission-based, all-
hazards approach for DOD's critical assets, the SCI Administrative 
Security Manual[Footnote 16]--DOD's primary guide for protecting SCI 
and SAP data and material[Footnote 17]--takes a contrasting approach 
that emphasizes the protection of information from unauthorized access. 
Specifically, the annual inspections of SCI and SAP facilities, 
conducted by program managers and the Defense Intelligence Agency, 
focus on information security rather than on mission assurance, and on 
human threats rather than on all potential hazards. These inspections 
are required to determine, for example, whether facilities regularly 
obtain threat assessments from a supporting law enforcement agency or 
counterintelligence office, but they are not required to verify the 
existence of threat assessments for natural disasters, accidents, 
public works or mechanical failure, or other diverse hazards. The 
manual also requires facilities to develop emergency action plans that 
outline policies, responsibilities, and procedures for protecting SCI 
and SAP material during emergencies. While these emergency action plans 
must consider a broad array of potential threats, they address only 
post-incident planning, and they do not discuss preventive measures, 
such as hardening facilities or enhancing redundancy. Unlike DCIP's 
critical asset policy, moreover, SCI and SAP policy contains no 
requirement that asset owners or operators report to ASD(HD&ASA) or 
another body the actions they have taken, as a result of vulnerability 
assessments, to assure the availability of their assets. These 
fundamental differences prevent DOD from applying consistent and 
comprehensive risk management across all of its critical assets. 

DCIP Assessments Are Feasible for SCI, but Unlikely for SAP Assets: 

Performing an infrastructure vulnerability assessment requires an 
understanding of the asset's mission and operating characteristics, 
which in the case of SCI or SAP assets is available only to authorized 
individuals. The Defense Threat Reduction Agency has assessment staff 
who possess SCI clearances, which has enabled it to perform non-DCIP 
assessments of SCI assets in the past. Therefore, it could also assess 
vulnerabilities of SCI assets as part of DCIP, should any unidentified 
SCI assets be identified as critical under the program. Officials at 
the Defense Intelligence Agency told us that its SCI facility 
inspection teams currently do not coordinate with the Defense Threat 
Reduction Agency's DCIP assessment teams, but could feasibly do so. 

Conversely, there have been no cases where Defense Threat Reduction 
Agency staff have been granted access to a SAP for the purpose of a 
vulnerability assessment, according to officials at the agency. Even if 
gaining access were possible, it might not be feasible. DOD officials 
responsible for SAP policy told us that the department operates more 
than 100 SAPs at any given time; vulnerability assessment staff would 
have to satisfy the individual access requirements of each SAP with 
critical infrastructure. Unless DOD develops a process for assessing 
SAP infrastructure that can satisfy DCIP standards and benchmarks while 
respecting the extraordinary sensitivity of SAP information, DOD will 
continue to lack sufficient information to make sound risk management 
decisions concerning critical SAP assets. 

Conclusions: 

DOD has taken significant steps toward identifying, prioritizing, and 
assessing vulnerabilities of the DOD-and non-DOD-owned infrastructure 
it relies on to plan, mobilize, deploy, execute, and sustain U.S. 
military operations globally. Having a complete list of prioritized and 
assessed critical infrastructure will enable DOD to target limited 
resources to its most mission-critical assets at highest risk. However, 
DOD's current practice of limiting its data collection and analysis to 
collateral-level infrastructure has resulted in the exclusion of an 
undetermined number of critical SCI and SAP assets from the 
department's list of critical infrastructure. This exclusion creates 
risk management challenges, impeding DOD's ability to make informed 
decisions about potentially serious risks to core defense missions. 
Until DOD devises an integrated approach to identify, prioritize, and 
assess all of its critical infrastructure--collateral, SCI, and SAP 
assets--or develops parallel approaches that use mission-based, all-
hazards criteria, DOD will lack the full awareness needed to assure 
mission success. 

Recommendations for Executive Action: 

To ensure that DOD adequately identifies, prioritizes, and assesses 
critical SCI and SAP infrastructure, we recommend that the Secretary of 
Defense direct ASD(HD&ASA) to take the following two actions: 

* Develop a process to identify, prioritize, and assess all critical 
SCI and SAP assets in a manner consistent with DCIP standards. As one 
option, ASD(HD&ASA) could partner with the Defense Intelligence Agency 
and the SAP Central Office to compile separate lists of, and to perform 
mission-based, all-hazards vulnerabilities assessments on, critical 
SCI and SAP assets. 

* Amend the DCIP Security Classification Guide to explicitly address 
the treatment of SCI and SAP information on critical asset lists. 

Agency Comments: 

In written comments on a draft of this report, DOD concurred with one 
recommendation and partially concurred with the other. DOD's comments 
are reproduced in full in enclosure I. DOD also provided us with 
technical comments, which we incorporated where appropriate. 

DOD partially concurred with our recommendation to develop a process to 
identify, prioritize, and assess all critical SCI and SAP assets in a 
manner consistent with DCIP standards. In its comments, ASD(HD&ASA) 
stated that it has begun working with its counterparts in the Defense 
Intelligence Agency and the SAP Central Office to formalize such a 
process. ASD(HD&ASA) also indicated that it plans to work with the 
Defense Threat Reduction Agency and the Defense Intelligence Agency on 
methodologies for assessing SCI assets. We believe that these two 
coordination efforts are necessary initial steps toward comprehensive 
risk management of DOD's highly sensitive critical infrastructure, and 
are consistent with the intent of our recommendation. Regardless of 
what approach it ultimately devises, as we recommended, DOD should 
ensure that it identifies and prioritizes all mission-critical SCI and 
SAP assets, and that it employs a mission-based, all-hazards analysis 
in assessing the assets' vulnerabilities. 

DOD concurred with our recommendation to amend the DCIP Security 
Classification Guide to explicitly address the treatment of SCI and SAP 
information on critical asset lists. In collaboration with the Defense 
Intelligence Agency and the SAP Central Office, ASD(HD&ASA) will issue 
interim guidance on this subject, and subsequently incorporate that 
guidance into a new DOD manual to supersede the Classification Guide. 

As agreed with your offices, we are sending copies of this report to 
the Chairmen and Ranking Members of the Senate and House Committees on 
Appropriations, Senate and House Committees on Armed Services, and 
other interested congressional parties. We also are sending copies of 
this report to the Secretary of Defense; the Secretary of Homeland 
Security; the Director, Office of Management and Budget; and the 
Chairman of the Joint Chiefs of Staff. We will also make copies 
available to others upon request. In addition, this report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-5431 or by e-mail at dagostinod@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff who 
made key contributions to this report are listed in enclosure II. 

Signed by: 

Davi M. D'Agostino:
Director:
Defense Capabilities and Management: 

Enclosures - 2: 

[End of correspondence] 

Enclosure I: 

Comments from the Department of Defense: 

Assistant Secretary Of Defense: 
Homeland Defense: 
2600 Defense Pentagon: 
Washington, DC 20301-2600: 

Ms. Davi M. D'Agostino: 
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

March 27, 2008: 

Dear Ms. D'Agostino: 

This is the Department of Defense (DOD) response to the GAO draft 
report, GAO-08-373R, "Defense Critical Infrastructure: DOD's Risk 
Analysis of Its Critical Infrastructure Omits Highly Sensitive Assets," 
dated February 28, 2008 (GAO Code 351157). DOD concurs with comment on 
both recommendations in the report. Our response to your 
recommendations is attached. 

Our point of contact for this action is Mr. Antwane Johnson, Office of 
the Assistant Secretary of Defense for Homeland Defense and Americas' 
Security Affairs (OASD (HD&ASA)), (703) 602-5730, Extension 143 or 
Antwane.Johnson@osd.mil. 

Sincerely, 

Signed by: 

Paul McHale: 

Attachment: As stated: 

GAO Draft Report  Dated February 28, 2008: 
GAO CODE 351157/GAO-08-373R: 

"Defense Critical Infrastructure: DOD's Risk Analysis of Its Critical 
Infrastructure Omits Highly Sensitive Assets" 

Department Of Defense Comments To The Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Assistant Secretary of Defense for Homeland Defense and 
Americas' Security Affairs (ASD(HD&ASA) to develop a process to 
identify, prioritize, and assess all critical Sensitive Compartmented 
Information (SCI) and Special Access Program (SAP) assets in a manner 
consistent with the Defense Critical Infrastructure Program (DCIP) 
standards. As one option, ASD(HD&ASA) could partner with the Defense 
Intelligence Agency and the SAP Central Office to compile separate 
lists of, and to perform mission-based, all-hazards vulnerabilities 
assessments on, critical SCI and SAP assets. 

DOD Response: Partially concur with comment. The DCIP Office is working 
with its counterparts in the Defense Intelligence Agency and the SAP 
Central Office to formalize a process that ensures that all critical 
Sensitive Compartmented Information (SCI) and Special Access Program 
(SAP) assets are identified, prioritized, and assessed by DOD as part 
of a comprehensive approach to risk management. 

The Intelligence, Surveillance, and Reconnaissance (ISR) Sector, an 
oversight body reporting to the Director, Defense Intelligence Agency 
(DIA), has developed a list of SCI assets. The list of over 80 SCI 
assets was developed, coordinated, and approved by the membership of 
the ISR Sector Working Group, which includes the national agencies 
(National Security Agency (NSA), National Reconnaissance Office (NRO), 
and National Geospatial Intelligence Agency (NGA)), DIA, the Service 
intelligence activities, and Combatant Command J2 staffs. This 
aggregate list of prioritized SCI assets, classified at the TS/SCI 
level, is being managed by DIA. 

As acknowledged by GAO, the Defense Threat Reduction Agency (DTRA) has 
an assessment staff who possess SCI clearances. DTRA has conducted 
Baseline Survivability Assessments (BSAs) and Full Spectrum 
Survivability Vulnerability Assessments (FSIVAs) at a variety of ISR 
Sector SCI assets including, among others, the national and defense 
intelligence agencies, the National Military Joint Intelligence Center 
(NMJIC), and several of the Command Headquarters, including their 
Intelligence Staff (J2). The DCIP Office will coordinate with DTRA and 
the ISR Sector regarding assessment methodologies. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Assistant Secretary of Defense for Homeland Defense and 
Americas' Security Affairs (ASD(HD&ASA) to amend the DCIP Security 
Classification Guide to explicitly address the treatment of Sensitive 
Compartmented Information and Special Access Program information on 
critical asset lists. 

DOD Response: Concur with comment. The DCIP Office, in collaboration 
with the DIA and the SAP Central Office will develop processes and 
procedures to explicitly address the treatment of Sensitive 
Compartmented Information and Special Access Program information on 
critical asset lists. OASD(HD&ASA) will issue interim guidance 
regarding the handling of SCI and SAP information on critical assets. 
This guidance will then be incorporated into a new DOD manual that will 
supersede the DCIP Security Classification Guide. 

[End of enclosure 1] 

Enclosure II: 

GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Davi M. D'Agostino, (202) 512-5431 or dagostinod@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Mark A. Pross, Assistant 
Director; Jonathan K. Bateman; Katherine S. Lenane; Danielle S. 
Pakdaman; Terry L. Richardson; Marc J. Schwartz; and Cheryl A. Weissman 
made key contributions to this report. 

[End of enclosure 2] 

Footnotes: 

[1] Earlier programs analogous to DCIP can be traced back to 1998. 
ASD(HD&ASA) has been responsible for developing and ensuring 
implementation of critical infrastructure protection policy and program 
guidance since September 2003. 

[2] Department of Defense, The National Defense Strategy of the United 
States of America (Washington, D.C.: March 2005). The National Defense 
Strategy outlines DOD's approach to the defense of the nation and its 
interests, establishing four strategic objectives: (1) secure the 
United States from direct attack, (2) secure strategic access and 
retain global freedom of action, (3) strengthen alliances and 
partnerships, and (4) establish favorable security conditions. 

[3] SCI is classified information concerning or derived from 
intelligence sources, methods, or analytical processes that is required 
to be handled within formal access control systems established by the 
Director of National Intelligence. 

[4] Executive Order 12958 states that a SAP shall be established only 
when the program is required by statute or upon a specific finding that 
the vulnerability of, or threat to, specific information is 
exceptional, and the normal criteria for determining eligibility for 
access to information classified at the same level is insufficient to 
protect the information from unauthorized disclosure. SAPs impose 
safeguarding and access requirements exceeding those normally required 
for collateral information at the same level of classification. 
Collateral-level information is information identified as national 
security information (Confidential, Secret, or Top Secret) but not 
subject to enhanced security protection required for SCI or SAP 
information. 

[5] GAO, Defense Infrastructure: Actions Needed to Guide DOD's Efforts 
to Identify, Prioritize, and Assess Its Critical Infrastructure, GAO-
07-461 (Washington, D.C.: May 24, 2007). 

[6] GAO, Defense Infrastructure: Management Actions Needed to Ensure 
Effectiveness of DOD's Risk Management Approach for the Defense 
Industrial Base, GAO-07-1077 (Washington, D.C.: Aug. 31, 2007). 

[7] The geographic combatant commands are the U.S. Central Command, 
U.S. European Command, U.S. Northern Command, U.S. Pacific Command, and 
U.S. Southern Command. (A sixth geographic combatant command, the U.S. 
Africa Command, remains subordinate to the European Command and, 
therefore, was not examined separately for this report.) The functional 
combatant commands are the U.S. Joint Forces Command, U.S. Special 
Operations Command, U.S. Strategic Command, and U.S. Transportation 
Command. 

[8] Homeland Security Presidential Directive 7, issued in December 
2003, requires, among other things, that all federal departments and 
agencies identify, prioritize, and coordinate the protection of 
critical infrastructure and key resources from terrorist attacks. DCIP 
encompasses the full spectrum of threats--ranging from terrorist 
attacks to natural disasters and catastrophic accidents--that can 
adversely affect critical defense infrastructure. 

[9] Draft DOD Instruction 3020.nn Defense Critical Infrastructure 
Program (DCIP) Management, undated. 

[10] In addition to the Defense Threat Reduction Agency and asset 
owners, the Defense Contract Management Agency and the National Guard 
also conduct DCIP assessments on defense industrial base assets using 
the same methodology. 

[11] ASD(HD&ASA), Defense Critical Infrastructure Program Assessment 
Standards and Benchmarks (May 30, 2006). 

[12] ASD(HD&ASA), Defense Critical Infrastructure Program (DCIP) 
Security Classification Guide (May 15, 2007) (For Official Use Only). 

[13] DOD, Department of Defense Overprint to the National Industrial 
Security Program Operating Manual Supplement (April 1, 2004). Executive 
Order 12958, as amended, calls for agency heads to establish and 
maintain systems of accounting for the SAPs created under their 
authority. 

[14] GAO-07-1077. 

[15] ASD(HD&ASA), Critical Asset Identification Process (draft) 
(September 1, 2007). 

[16] DOD 5105.21-M-1, Sensitive Compartmented Information 
Administrative Security Manual, Defense Intelligence Agency (August 3, 
1998) (For Official Use Only). 

[17] DOD officials responsible for SAP policy told us that SCI security 
standards, including the SCI Administrative Security Manual, are used 
to determine the baseline measures required to safeguard SAPs. The 
standards are then supplemented by measures described in the program 
security guides of each individual SAP. 

[End of section] 

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