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S. HRG. 114–597 

NOMINATION OF SUSAN GIBSON TO BE 

INSPECTOR GENERAL OF THE NATIONAL 

RECONNAISSANCE OFFICE 

HEARING 

BEFORE THE

SELECT COMMITTEE ON INTELLIGENCE 

OF THE

UNITED STATES SENATE 

ONE HUNDRED FOURTEENTH CONGRESS 

SECOND SESSION 

TUESDAY, JUNE 7, 2016 

Printed for the use of the Select Committee on Intelligence 

( 

Available via the World Wide Web: http://www.fdsys.gov 

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(II) 

SELECT COMMITTEE ON INTELLIGENCE 

[Established by S. Res. 400, 94th Cong., 2d Sess.] 

RICHARD BURR, North Carolina, Chairman 

DIANNE FEINSTEIN, California, Vice Chairman 

JAMES E. RISCH, Idaho 

DANIEL COATS, Indiana 

MARCO RUBIO, Florida 

SUSAN COLLINS, Maine 

ROY BLUNT, Missouri 

JAMES LANKFORD, Oklahoma 

TOM COTTON, Arkansas 

RON WYDEN, Oregon 

BARBARA A. MIKULSKI, Maryland 

MARK WARNER, Virginia 

MARTIN HEINRICH, New Mexico 

ANGUS KING, Maine 

MAZIE K. HIRONO, Hawaii 

MITCH MCCONNELL, Kentucky, Ex Officio 

HARRY REID, Nevada, Ex Officio 

JOHN MCCAIN, Arizona, Ex Officio 

JACK REED, Rhode Island, Ex Officio 

CHRIS JOYNER, Staff Director 

MICHAEL CASEY, Minority Staff Director 

DESIREE THOMPSON SAYLE, Chief Clerk 

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(III) 

CONTENTS 

JUNE 7, 2016 

OPENING STATEMENTS 

Burr, Hon. Richard, Chairman, a U.S. Senator from North Carolina ................ 1 

Feinstein, Hon. Dianne, Vice Chairman, a U.S. Senator from California .......... 2 

WITNESS 

Gibson, Susan, Nominated to be Inspector General of the National Reconnaissance Agency ........................................................................................................ 3 

Prepared statement .......................................................................................... 6 

SUPPLEMENTAL MATERIAL 

Letter dated June 3, 2016, from Benjamin A. Powell to Senator Richard 

Burr and Senator Dianne Feinstein ................................................................... 26 

Letter dated June 6, 2016, from Stephanie Barna to Senator Richard Burr 

and Senator Dianne Feinstein ............................................................................ 28 

Letter dated June 4, 2016, from John C. Inglis to Senator Richard Burr 

and Senator Dianne Feinstein ............................................................................ 30 

Letter dated June 3, 2016, from Robert S. Litt to Senator Richard Burr 

and Senator Dianne Feinstein ............................................................................ 32 

Questionnaire for Completion by Presidential Nominees .................................... 34 

Additional Prehearing Questions ........................................................................... 49 

Letter dated April 25, 2016, from the Office of Government Ethics to Senator 

Richard Burr ......................................................................................................... 67 

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(1) 

NOMINATION OF SUSAN GIBSON TO BE 

INSPECTOR GENERAL OF THE NATIONAL 

RECONNAISSANCE OFFICE 

TUESDAY, JUNE 7, 2016 

U.S. SENATE, 

SELECT COMMITTEE ON INTELLIGENCE, 

Washington, DC. 

The Committee met, pursuant to notice, at 2:31 p.m. in Room 

SH–216, Hart Senate Office Building, Hon. Richard Burr (Chairman of the Committee) presiding. 

Committee Members Present: Senators Burr, Feinstein, Risch, 

Rubio, Collins, Blunt, Cotton, Wyden, Heinrich, King, and Hirono. 

OPENING STATEMENT OF HON. RICHARD BURR, CHAIRMAN, A 

U.S. SENATOR FROM NORTH CAROLINA 

Chairman BURR. I’d like to call the hearing to order. 

Ms. Gibson, congratulations on your nomination to be the first 

advised and consent Inspector General for the National Reconnaissance Office. You have an impressive background both within the 

intelligence community and the Department of Defense, which I believe will serve you well in your new assignment. 

I’d also like to welcome your husband Tim, who is in the audience today, and I thank him both for his support for you and his 

distinguished service to our country. 

In many cases, inspector generals are the eyes and ears of their 

respective agencies’ leadership, and they can be for Congress as 

well. Through critical oversight of the Executive Branch operations, 

they can provide useful assessments of performance and identify 

areas for improvement. We need efficiency of effort across government now more than ever. I feel strongly that effective and independent inspector generals can help us achieve that goal. 

The NRO’s classified budget is significant, and the NRO Inspector General plays a vital oversight role in detecting and hopefully 

deterring any fraud, waste, or abuse within the NRO. As we conduct our own oversight of the NRO, we may look to your office for 

its opinions on the programs that are functioning well or may need 

improvement. 

As the NRO’s Inspector General, much of your work will of necessity be classified. This means that there will most often not be 

public airings of your assessments. As a result, Congress and the 

American people must have full confidence that your findings are 

objective, independent, and entirely supported by the facts. 

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2 

Ms. Gibson, I’ve reviewed the material provided by you prior to 

this confirmation hearing and have spoken with you personally. I’m 

confident that you’re a person of high integrity and well qualified 

for this job. Thank you again for being here today, for your years 

of service to our country, and I look forward to your testimony. 

I now recognize the Vice Chairman. 

OPENING STATEMENT OF HON. DIANNE FEINSTEIN, VICE 

CHAIRMAN, A U.S. SENATOR FROM CALIFORNIA 

Vice Chairman FEINSTEIN. Thanks very much, Mr. Chairman. 

I want to congratulate our prospective Inspector General. I’d like 

to welcome her family, and maybe next time we’ll get a smaller 

room. But we should all feel very comfortable; plenty of space. 

In 2013 this Committee included in the Intelligence Authorization Act a requirement for Senate confirmation of the inspectors 

general for the National Reconnaissance Office and the National 

Security Agency. So, Ms. Gibson, you’re the first nominee to be considered by the Senate for the NRO position. 

This month the NSA Inspector General will be stepping down, 

and the CIA has been without a Senate-confirmed inspector general since January of 2015. Given the importance of IGs, I believe 

these gaps in service are unacceptable. Last June I wrote to the 

President to urge him to nominate an IG for the CIA. Today I 

renew this request and ask him to ensure NSA does not languish 

without a Senate-confirmed IG. 

Ms. Gibson, you and I recently had the opportunity to meet and 

discuss your nomination, and I want you to know that I personally 

appreciated our frank discussion, which demonstrated your understanding of the role of the IG and the need to be principled, objective, and effective in your oversight of virtually every aspect of the 

NRO. 

If confirmed, it will be your job to ensure that the NRO remains 

free of waste, fraud, and mismanagement, while avoiding 

politicization of the office. You will also have to support efforts to 

drive the organization toward more efficient and effective operations. I believe that you have the background to carry out this 

mission. 

It’s also important that you recognize, which I believe you do, 

your responsibility to keep this committee fully and currently informed about the concerns you may identify at the NRO. I don’t 

want to sugarcoat it, but this is really a big job. It’s a big job in 

part due to NRO’s size and the complexity of its mission. You’re 

going to be required to dig deep into some very technical and complicated programs, including some of the most classified and also 

expensive programs. 

But it’s also a big job because it comes with an extra responsibility of conducting oversight of an organization in which most activities are conducted in secret. The duty to the American public 

cannot be overstated here. This committee is charged with ensuring the intelligence community operates in a manner that’s legal, 

efficient, and abides by the values of the American people. This requires effective and independent inspectors general to support us 

in this task. 

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3 

So it’s our expectation that, if confirmed, you will make full use 

of the authorities provided to you as an inspector general and keep 

this committee clearly advised. So I will ask in my question time 

how you intend to do our oversight, so that the committee can understand your vision for this office. 

So congratulations on the nomination and thank you for being 

here. I look forward to our discussion. 

Thanks, Mr. Chairman. 

Chairman BURR. Thank you, Vice Chairman. 

Ms. Gibson, I’m going to ask you to stand and raise your right 

hand. 

Do you solemnly swear to give this committee the truth, the full 

truth, and nothing but the truth, so help you God? 

Ms. GIBSON. I do. 

TESTIMONY OF SUSAN GIBSON, NOMINATED TO BE INSPECTOR GENERAL OF THE NATIONAL RECONNAISSANCE OFFICE 

Chairman BURR. Please be seated. I’ll ask you to answer the five 

standard questions the committee poses to each nominee who appears before us. They just require a simple yes or no answer for 

the record. 

One, do you agree to appear before the committee here and in 

other venues when invited? 

Ms. GIBSON. Yes, sir. 

Chairman BURR. Two, if confirmed do you agree to send officials 

from your office to appear before the committee and designated 

staff when invited? 

Ms. GIBSON. Yes. 

Chairman BURR. Three, do you agree to provide documents and 

any other materials requested by the committee in order to carry 

out its oversight and legislative responsibilities? 

Ms. GIBSON. Yes. 

Chairman BURR. Four, will you both ensure that your office and 

your staff provide such materials to the committee when we request it? 

Ms. GIBSON. Yes. 

Chairman BURR. And five, do you agree to inform and fully brief 

to the fullest extent possible all members of this committee of intelligence activities and covert action, rather than only the Chair and 

the Vice Chair? 

Ms. GIBSON. Yes, sir. 

Chairman BURR. Thank you very much, Ms. Gibson. 

We’ll now proceed to your opening statement, after which I’ll recognize members by seniority for five minutes each of questions. The 

floor is yours. 

Ms. GIBSON. Thank you very much, Chairman. Good afternoon, 

Chairman Burr, Vice Chairman Feinstein, and distinguished members of the committee. Thank you for the opportunity to appear before you today as you consider my nomination to be the Inspector 

General for the National Reconnaissance Office. I also appreciate 

the opportunity I’ve had to meet with several of you and to hear 

your concerns for the NRO and for the intelligence community at 

large. 

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4 

I’m deeply honored that the President nominated me for this position and I’m grateful for the support of both Director Clapper and 

Director Sapp. If confirmed, I look forward to working with you, 

with Director Sapp, and with the fine women and men of the NRO 

and the NRO Inspector General’s Office to further the NRO’s mission. 

Before going any further, I would like to recognize my husband 

Tim, who joins me here today. A week from today is our 36th wedding anniversary. Tim and I met in high school and both had full 

Army careers. We supported each other all along the way. It was 

very much a team. We had a great deal of fun and we’ve raised 

two amazing daughters, Katie and Joanna, who are both here in 

spirit, but have very busy, full, and interesting lives and couldn’t 

make it, unfortunately. 

I’d also like to acknowledge publicly the support I’ve received 

from my parents, but particularly from my mother, Claudette 

Green. I’m the first person in my family, which includes my brother, my sister, and nearly 20 cousins, to graduate from college. I 

couldn’t have accomplished this without the love and support of my 

remarkable mother, who’s now 80. But, like my daughters, she is 

still busy and leading a very full life and is unable to join us today. 

I would like to thank my friends, my co-workers, many of whom 

are here today—thank you—and my many mentors. Life is a team 

sport and so is public service. As one of my mentors, Stephanie 

O’Sullivan, says: ‘‘There’s no end to what we can accomplish if we 

don’t care who gets the credit.’’ I couldn’t agree more, and I’m 

thankful for the wonderful team that helped me along the way. 

To briefly address my qualifications for this position, my 22 years 

in the Army JAG Corps encompassed a broad legal practice, to include criminal law and investigations, government contracting and 

fiscal law, international agreements, domestic and international 

crisis response, human intelligence operations, and privacy and 

civil liberties. My time in the Army also impressed on me the importance of building and nurturing strong teams and effective 

teams. 

I joined the intelligence community while I was still wearing my 

Army colonel’s uniform, first at the Defense Intelligence Agency 

and then as part of DNI Negroponte’s original legal team. I later 

retired from the Army and joined the civilian ranks at ODNI. I’ve 

supported all four DNIs and have touched on virtually every aspect 

of the mission. I helped stand up the office, assisted with drafting 

multiple intelligence community policies, helped rewrite Executive 

Order 12333, and regularly provided advice and counsel as we 

worked through many issues affecting the intelligence community. 

As a result of these experiences, I’m well grounded in intelligence 

law and policy and in many other areas of law relevant to the mission of the NRO and its Inspector General, to include fiscal law, 

whistleblower protections, ethics, procurement law, and procurement integrity. 

Most important, during my years in government I’ve learned and 

re-learned the importance of conducting a careful and unbiased 

analysis of the facts and the law, acting with integrity and honesty 

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5 

tions of good government and they are also foundational to conducting effective oversight. 

My experience at ODNI has made me acutely aware of the essential role of the NRO in the national security of this country. I’m 

also aware of the growing risks to NRO’s mission. 

I recognize that if I’m confirmed this committee will have high 

expectations for my performance and for the performance of the 

NRO IG’s office. I share those same expectations. If confirmed, I 

pledge to continue the office’s legacy of excellence, to use my many 

years of experience to reduce risks and to improve the NRO’s efficiency and effectiveness. 

Finally, I also recognize and indeed embrace Congress’ oversight 

of the NRO. Congressional oversight is fundamental to the checks 

and balances established in our Constitution and the only way that 

the intelligence community can effectively operate in our open and 

democratic society. If confirmed, I will fully support the NRO IG’s 

notification and reporting responsibilities and keep the NRO’s oversight committees fully and currently informed. 

I’m under no illusion that fulfilling the responsibilities of this 

new position will be easy. If confirmed, I pledge to do my very best 

as I continue to serve my Nation. 

Thank you again for your consideration of my nomination and I 

look forward to taking your questions. 

[The prepared statement of Ms. Gibson follows:] 

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Statement for the Record 

Ms. Susan Gibson 

Nominee for Inspector Genera~ of the Nationa~ Reconnaissance Office 

Senate Se~ect Committee on Inte~~igence 

7 June 2016 

Chairmen Burr, Vice Chairman Feinstein, and distinguished members 

of the Committee, thank you for the opportunity to appear before you 

today as you consider my nomination to be the Inspector General for 

the National Reconnaissance Office (NRO) . I also appreciate the 

opportunity I've had to meet privately with several of you to hear 

your concerns and your goals for the NRO and the Intelligence 

Community. I am deeply honored to have been nominated by the President 

for this position, and I am grateful for the support and encouragement 

I have received from Director Clapper and Director Sapp. If confirmed, 

I look forward to working with you, with Director Sapp, and with the 

fine women and men of the NRO and the NRO Inspector General's Office 

to further the NRO's mission. 

I appreciate the opportunity to introduce my husband of 35 years, 

Tim. Tim and I met in high school and both had full Army careers, 

supporting each other along the way and raising two daughters we're 

extremely proud of: Katie and Joanna, who are both here in spirit, but 

busy with their full and interesting lives. I would also like to take 

a moment to thank my parents, but particularly my mother, Claudette 

Greene. I am the first person in my extended family, which included 

my brother and sister and nearly 20 cousins, to graduate from college. 

1 
7 

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I could never have accomplished this without the love and support of 

my remarkable mother, who is now 80, but like the rest of my family, 

still leading a busy life. I would also like to recognize my friends, 

my co-workers, and my many mentors throughout my career. As one of my 

mentors is fond of saying, life is a team sport and nthere is no end 

to what we can accomplish if we don't care who gets the credit." I 

couldn't agree more, and am very thankful for the wonderful team that 

helped me along the way. 

The majority of my 30-plus year career has been in the national 

security field, with the last 15 years largely concentrated on the 

intelligence community. My 22 years in the Army included a broad range 

of military legal practice, to include criminal law and 

investigations, government contracting and fiscal law, international 

agreements, domestic and international crisis response, privacy and 

civil liberties, human intelligence operations, and rule of law. As 

part of the original legal team for the Director of National 

Intelligence (DNI), I have provided support to all four DNis and have 

touched on virtually every aspect of the mission. I helped stand up 

the Office of the Director of National Intelligence (ODNI), and 

assisted with drafting multiple Intelligence Community Directives and 

related policies, helped re-write Executive Order 12333, and regularly 

provided advice and counsel as the ODNI worked through many issues 

affecting all seventeen Intelligence Community elements. As a result 

of these experiences, I am well grounded in intelligence law and 

policy, and in many other areas of law relevant to NRO's mission, to 

include fiscal law, and government procurement law and procurement 

2 
8 

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integrity. Most important, during my years in government I've learned 

and relearned the importance of conducting a careful and unbiased 

analysis of the facts and the law, acting with integrity and honesty, 

and proceeding with openness and inclusion. These are the foundations 

of "good government," and are also foundational to conducting 

effective oversight. 

The NRO Office of Inspector General continues to enjoy a 

reputation for excellence in its oversight activities, all while 

undergoing a series of transitions, to include numerous changes in 

executive leadership. I recognize that, if confirmed, this committee 

will have high expectations for my performance and the performance of 

the office. I share those same expectations. If confirmed, I pledge 

to continue the office's legacy of excellence by providing principled 

and steadfast leadership, and strategic vision. 

My experience at ODNI has made me acutely aware of the essential 

role of the NRO in the national security of this country and also 

aware of the growing risks to NRO's mission. It has also sensitized 

me to the need for strong oversight of NRO's processes and its mission 

execution. If confirmed, I will use my many years of experience to 

identify opportunities to reduce risks and to improve the efficiency 

and effectiveness of the NRO. 

I also recognize and embrace Congress' need to exercise effective 

oversight of the NRO, along with the rest of the Intelligence 

Community. Congressional oversight is fundamental to the checks and 

balances established in our Constitution and the only way the 

3 
9 

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Intelligence Community can effectively operate in our open and 

democratic society. If confirmed, I will fully support the NRO IG's 

notification and reporting obligations and keep the NRO's oversight 

committees fully and currently informed. 

I am under no illusion that fulfilling the responsibilities of 

this new position will be easy. If confirmed, I pledge to do my very 

best as I continue to serve my nation. 

Thank you again for your consideration of my nomination. 

4 
10 

Chairman BURR. Ms. Gibson, thank you. I thank your husband, 

your daughters, and, yes, I even thank your mother for the fact 

that she made sure you made it through the gauntlet of education 

and bring your expertise to a critical role at the NRO. 

With that, I’ll recognize myself and then the Vice Chairman and 

then by seniority the members. 

I’ve met with the NRO leadership many times and stressed the 

need for the organization to streamline their processes to more rapidly and affordably field capabilities with the latest technologies. 

As is typically the case, it’s difficult to have a large organization 

make fundamental changes in acquisition practices without sustained and constant oversight. 

Two questions: Can you describe how the IG currently reviews 

the acquisition of satellite systems at NRO? And how often are investigators reviewing program management to ensure resources 

are efficiently and effectively managed? 

Ms. GIBSON. Chairman, as we discussed briefly before this hearing, I think we both share the same concerns about acquisition and 

the need to streamline acquisition to stay ahead of the curve in 

technology and keep our edge in this world, where technology is 

driving things more and more. 

It is something that I have given a great deal of thought to, as 

to how to go about doing this at the NRO. I think it is the same 

in many other areas. Effective oversight would include the audits, 

the inspections, being present, being there, being receptive to the 

sorts of complaints and concerns that people bring to you, and by 

being a partner oftentimes in the mission and taking problems and 

taking recommendations to the leadership often. 

I quite frankly am not familiar yet with how often they’re doing 

these inspections and audits. NRO has passed its audits for the 

last several years, which is encouraging and something I hope to 

continue and encourage as the IG. But it’s something that I think 

would be clearly a priority and a focus if I was confirmed to be the 

IG at the NRO. 

Chairman BURR. Good. 

Would your office be ready and willing to support our efforts to 

identify organizational or procedural changes required to help the 

NRO become more agile and cost-competitive in their acquisition 

process? 

Ms. GIBSON. Certainly, sir. 

Chairman BURR. Great. With that, I’ll turn to the Vice Chairman. 

Vice Chairman FEINSTEIN. Thanks very much, Mr. Chairman. 

Ms. Gibson, a key purpose of this hearing is to ensure that the 

nominee understands the independent role of the IG in a secret organization like the NRO, and that Congress depends on an independent, impartial IG to pursue allegations of malfeasance such as 

the NRO has faced in the past. 

The now-retired previous NRO IG, Lanie D’Alessandro, has been 

quoted in the press as saying, and I quote: ‘‘If you’re going to do 

this job, well, you risk your future job aspirations. It’s best you 

take the job as a swan song before you retire.’’ End quote. 

From your knowledge, do you agree with this statement? And 

what impediments to your independence do you foresee, and how 

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11 

would you ensure your complete independence, upon which this 

committee relies? 

Ms. GIBSON. Vice Chairman Feinstein, it’s hard to say whether 

I agree with that statement, not having been in the position. I 

think I’m more comfortable answering for you how I would keep 

my independence and sort of my own personal views on independence. 

For better or worse, I am at that part of my career where this 

may well be my swan song, so I can start there. However, I don’t 

think that’s necessary. I’ve been an attorney, a deputy general 

counsel, for many years. I’ve given a lot of advice to people, advice 

that they didn’t necessarily want to hear. My experience has been 

if you’re open, if you’re honest, if you’re unbiased, and if you’re giving advice and overseeing things in the correct spirit, to improve 

things, to find efficiencies, not to grind axes, that people are more 

than willing to listen to you, even when they find it difficult. 

They may grumble at you. They may not be happy to see you 

come into their office as the ethics official for an agency. I’ve had 

this happen several times. People aren’t necessarily happy to see 

you come through the door. 

But if you give them a day or two, they’ll almost always thank 

you for your honest advice. And that’s been my experience, and I 

think much of it has to do with your own personal integrity and 

how you approach the position. 

I think the structures of the NRO’s IG office are set up well for 

that independence. I think the fact that you have a potential appointed Inspector General before you today adds to that independence, and I believe that that is a lot of the reason that you set up 

this position that way. I think it will add to that independence and 

the ability to be independent. It’s something that I will guard and 

grow, I hope, for the office. 

Vice Chairman FEINSTEIN. Thank you. 

In your pre-hearing questions you noted that the current staffing 

allocation for the office—and I quote—‘‘may limit its ability to recruit and retain personnel with the skills necessary to fully perform its mission.’’ Could you expand on that comment and describe 

how the current NRO staffing allocations are limiting personnel recruiting and retention in the IG’s office? 

Ms. GIBSON. Yes, ma’am. As you know, the NRO has instituted 

a new system of cadre employees. I was surprised to find out how 

few of the personnel in the NRO IG’s office are cadre, as opposed 

to detailees from other agencies. 

My answer said it may be an impediment. I don’t have yet 

enough information to know for sure, but I think it’s one of those 

things that as the NRO sort of matures this personnel process, the 

IG’s office itself needs to take a good hard look at that and figure 

out what we need for cadre, what is appropriate to have on maybe 

a rotational basis or as detailees. 

I also think that the NRO across the board and the NRO’s IG 

office to perform effective oversight needs some skill sets that are 

sometimes hard to come by. It’s very high technology fields. Auditors are also sometimes in short supply. So the sorts of incentives 

you need, the sorts of professional development you need to ensure 

that people’s skills stay current and sharp and to ensure that they 

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12 

have the skills needed to oversee these highly technical programs, 

are something that are going to require constant nurturing if I’m 

confirmed as the IG. 

Vice Chairman FEINSTEIN. Let me just quickly point out that I 

think you have raised the Achilles’ heel of these agencies, and 

that’s rotating people in and rotating them out, because when they 

go out they go back to certain—a certain agency in the intelligence 

community, and that may limit their ability to really be fully invested in openness and honesty no matter what the cost. 

So I appreciate your knowledge of that and will be very interested to see what you will do and how you handle this issue. 

Ms. GIBSON. Thank you, ma’am. 

Chairman BURR. Senator Collins. 

Senator COLLINS. First of all, Ms. Gibson, I want to congratulate 

you on your nomination and your willingness to accept this important responsibility. 

I would like to hear your views on how you would propose to deal 

with, and indeed welcome, the input of whistleblowers within the 

agency? Recently there have been press reports that suggest that 

whistleblowers in the U.S. Central Command have brought forth 

complaints about how certain intelligence reports were treated. In 

addition, we have seen cases from the VA in which whistleblowers 

appear to have been the subject of retaliation and the individuals 

against whom they were bringing complaints were rewarded with 

bonuses and promotions. 

What would you do to ensure that whistleblowers have easy access to your office and that their complaints are carefully scrutinized, screened, and when appropriate acted upon? 

Ms. GIBSON. Senator Collins, I think you frame it well in your 

question. It’s really a two-part process. One is making sure that 

people are encouraged to reach out and that they have the information they need to find you to reach out, and that you make it as 

easy as you can for them to reach out to you, in confidence if necessary. So I think on the front end, if I were confirmed, one of the 

first things I would do is look at all the policies and processes that 

are in place to both inform the workforce, to include the contractor 

employee workforce, which is such a big part of NRO’s mission, to 

inform them of their ability to come to the IG’s office with any complaints or concerns, and then to make sure that all of the mechanisms for receiving those complaints and concerns are easy to find, 

easy to use, and confidential when necessary. 

So I think that’s the front end of it, is to encourage those sorts 

of complaints and concerns and that they be brought to us. Once 

they come in, then it’s crucial that you handle them appropriately, 

that you look into them quickly, and that they are a valid complaint, that they’re fully investigated, as many of the items that 

you listed with the VA and Central Command IG’s are now looking 

into those. I think that’s very important, for people to know that 

when once a complaint is brought forward something happens to it. 

Someone really looks at it and looks at it fully and fairly and takes 

care of it. 

If there are reprisals or threats of reprisal for people who bring 

forward these complaints, as you know, under the IG Act that’s 

considered an urgent concern and it’s a very serious matter, and 

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13 

that would require immediate reporting to the Director of the NRO 

and within seven days to the oversight committees, because it’s 

that serious if there’s reprisals or threat of reprisals against potential whistleblowers. I think quick action to take care of anyone who 

starts a reprisal action or threatens a reprisal action also then 

feeds the willingness of people to come into the system in the front 

end and make those complaints and take care of things if that’s 

simply not tolerated on the back end. 

Senator COLLINS. Thank you. 

Some inspectors general have experienced problems in getting access to documents that they need in order to conduct and complete 

their investigations. Should you encounter that sort of stonewalling 

or noncooperation with an investigation, would you report that to 

this committee? 

Ms. GIBSON. Senator Collins, if something like that happened— 

and it’s one of the first things I actually asked the staff at the NRO 

when they briefed me a few weeks ago, and they assured me that 

they haven’t had those problems there, and I think that says a lot 

about the office itself. 

But it’s certainly something I would guard against, and if I felt 

like I wasn’t getting the information that I needed I would first try 

to resolve it at the lowest level. It’s typically the best way to go. 

Sometimes it’s a misunderstanding. And I’d bring it to the leadership of the NRO. I’d advise them to work with their general counsel to get advice on whether it was proper to withhold the information. 

If it came down to it, I would certainly inform this committee 

and seek whatever assistance I needed, use subpoena authority if 

appropriate and if necessary. There are many ways to make that 

happen. And I would certainly inform this committee and request 

any assistance I thought I needed. 

Senator COLLINS. Finally, since my time has almost expired, I 

would just urge you to focus on NRO’s acquisition policies and 

major acquisitions. In my experience as head of the—when I was 

Chairman of the Homeland Security Committee, which was and is 

the major oversight committee in the Senate, we found that the 

IGs were invaluable in identifying acquisition problems, often before they resulted in cost overruns or contract failures, particularly 

in the information technology area. 

So I will write a question for the record on that to submit to you. 

But I would urge you to give that area your attention. Thank you. 

[The information referred to was not available at the time of publication.] 

Ms. GIBSON. Thank you, Senator. 

Chairman BURR. Senator Wyden. 

Senator WYDEN. Thank you very much, Mr. Chairman. 

Ms. Gibson, thank you for being here and for your many years 

of public service. I share the view of the Chair and the Vice Chair. 

This is a really important job. In particular, your office is in the 

position of awarding very large government contracts in secret. So 

it’s absolutely essential to have oversight from a strong inspector 

general. 

Now, my colleague from Maine has, as is usually the case, asked 

very good questions on this issue of whistleblowers, and I want to 

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14 

just follow it up in one regard. Chairman Grassley is the chair of 

the Whistleblowers Caucus. I am the vice chair. As you know, there 

have been these press reports over the years alleging retaliation 

against whistleblowers by senior officials. 

I’m not asking you to confirm the reports, but I think that any 

NRO employee who read those press reports might conclude that 

going to the Inspector General to warn that taxpayer dollars are 

being ripped off could be hazardous to their career. 

Just two questions: Do you understand why employees would feel 

that way? 

Ms. GIBSON. Certainly, sir. If they read reports like that, I can 

understand why they might. 

Senator WYDEN. I’d like to know whether, if confirmed—I believe 

you will be confirmed; I’ve heard only good things about your service. When you’re confirmed, are you going to have a meeting with 

the employees and inform them about how they will be protected 

from retaliation? Because I think that’s really one of the keys when 

there’s a history, that somebody new comes in, brings them all together, and says: This is how you will be protected from retaliation. 

Will you do that? 

Ms. GIBSON. Senator, I’ll make it a priority. 

Senator WYDEN. Can’t ask for more than that. 

One last question with respect to kind of policy issues. I think 

what I’ve learned over the years is it’s typically easier for inspector 

generals to investigate cases of wrongdoing by a single individual 

than it is to look at these systemic problems in major programs, 

because when you look at the bigger problems you often run into 

resistance. You’ve got the sort of status quo kind of crowd. 

How do you plan to ensure that your investigators aren’t afraid 

to ask hard questions and to really look at the big kind of problems, which historically is where you bump up against most resistance? And I think that’s what the Vice Chair was talking about 

with the comments, and I’ve got a whole sheaf of these comments. 

How do you think you can help to set the climate so that the big 

problems are going to be investigated? 

Ms. GIBSON. Senator, I believe that it would start with how you 

develop your workplan every year. The Investigations Section 

would be where I would look to for those sort of single bad actor 

sorts of investigations that you mentioned. I think it’s the Inspections and Audits Sections that I would actually look to for these 

larger, potentially systemic issues. 

I think speaking with all of the stakeholders, coming to this committee to get your views on things that you may be seeing that 

you’d like looked into, having an open mind, sitting down and taking the time to sort of step back and get out of the daily grind for 

a while you work on this long-range plan and think strategically 

about what the larger problems may be. And I think they’ve set up 

a pretty good process for that at NRO that I’ve seen for developing 

their work plan. It’s something I would want to look into more and 

perhaps refine after I got there, if I’m confirmed, and roll along as 

the year goes. 

I believe they’re in the middle of a work year now, so there 

should be some opportunity coming into the next work year to effect that plan. But I would certainly also look to this committee 

LAP51NQ082 with DISTILLER

15 

and the other oversight committees for any systemic issues that 

you’re seeing to feed into that work plan for inspections and audits. 

Senator WYDEN. I’m planning to support your confirmation and 

look forward to your service. Thank you. 

Ms. GIBSON. Thank you, sir. 

Chairman BURR. Senator Heinrich. 

Senator HEINRICH. Thank you, Mr. Chairman, and thank you for 

holding this hearing today. 

I want to say congratulations, Ms. Gibson, on your nomination. 

Thank you for joining us today for one of our rare open hearings. 

I see from your record that you not only have a distinguished 

legal career, but a long and distinguished military career as well. 

So thank you for your continued service to our country, and I certainly wish you well. 

The role of the Inspector General is critical. We rely on them and 

their staffs to conduct robust, independent review and oversight of 

agency activities, and to give us assurances that federal agencies 

are meeting the letter and the spirit of the law in carrying out 

their duties. 

For these reasons, I’d like to state for the record my concern that 

the Administration has not nominated a new Inspector General for 

the CIA in almost a year and a half, ever since David Buckley left 

the office in January of 2015. A position of such importance should 

not be vacant and I am disappointed that the Administration has 

not made this the higher priority. 

As I noted, the independence of the IG in any agency is central 

to our confidence that the investigations are conducted objectively 

and fairly. This benefits both the complainant and the target of an 

investigation. It’s also why this committee took steps to make the 

NRO IG a presidentially appointed and Senate-confirmed position. 

In fact, you will be the first NRO IG to be Senate-confirmed, a distinction that I am sure has not been lost on you. 

Being able to raise difficult issues with senior officials and agency directors is a prerequisite, a necessary quality for an IG. So in 

your opinion, what are the measurable indicators of real independence for an IG? And more specifically, what actions would you take 

if a senior IC official sought to somehow prevent you from conducting an adequate audit or investigation? 

Ms. GIBSON. Sir, if I thought that someone, a senior official or 

anyone, at NRO or in the intelligence community was seeking to 

impede an investigation or an audit, I would first have a conversation with them if it was a senior official, straight up have that conversation. The Secretary of Defense is the only person that I read 

about in the statute who has the authority to do that, and only for 

a vital national security interest, after consultation with the DNI. 

If it were that sort of a reason, that requires then a notification to 

the committees that that investigation or audit has been stopped 

for those reasons. 

Otherwise, I would come to this committee if I couldn’t resolve 

it myself, if there weren’t ways to work through it. I think oftentimes it’s just a matter of having open and honest conversations. 

I’m reminded, quite frankly, of my time in the JAG Corps, which 

typically we weren’t on the firing line and in the front lines, although that’s changed over time, unfortunately. We used to talk 

LAP51NQ082 with DISTILLER

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about those moments as a ‘‘JAG Purple Heart moment,’’ where you 

would go into the office and you just stand up and say what you 

had to say and take the hits if you took the hits. And like I said, 

eventually, a day or two later, they would usually come around and 

say: Thank you; I needed to hear that, and let’s work through it. 

I don’t have a problem doing that when I need to, and I think 

I’ve had lots of practice at it. And if I need to do it, if I’m confirmed 

as the IG, I’m ready to do it. 

Senator HEINRICH. I think we all appreciate your candor. It’s 

critical for this role. 

Although the NRO IG is independently appointed and confirmed, 

you’re still accountable to the IC IG and to the Department of Defense IG. What is your view of those relationships and how will you 

manage potential disagreements with either entity? 

Ms. GIBSON. Senator, I can’t think of a better experience for 

learning how to deal with the interface between the intelligence 

community and the DOD than my nearly 11 years at the ODNI, 

particularly having come out of DOD. I find the more that I deal 

with these issues, there are rarely conflicts that can’t be resolved. 

Typically, when you get to the bottom of any issue or problem, if 

you’re looking at it in a good government way and a way where you 

can make helpful progress moving forward, people’s interests start 

to align. That’s what I tend to look for when I start seeing those 

conflicts, as I start looking for where the interests align, and bring 

both parties to the table and have that open and honest discussion 

to find those areas. 

I’ve found typically, if you do that, you can and you can make 

progress and move forward in a cooperative way. That’s what I 

would seek to do. 

Senator HEINRICH. I just want to say thank you for your willingness to serve in this position. It takes a lot to put yourself out 

there, and I think we all appreciate it very much. 

Ms. GIBSON. Thank you, sir. 

Senator HEINRICH. Thank you, Chairman. 

Chairman BURR. Senator Rubio. 

Senator RUBIO. Thank you. 

Ms. Gibson, in your opening statement you take credit for helping stand up the Office of the Director of National Intelligence and 

to rewrite Executive Order 12333. Can you describe—and perhaps 

you have, and I apologize; I had another committee meeting—your 

role and how you wrote this order? 

Ms. GIBSON. Initially there was a team of two, me and the Chief 

of Policy at ODNI, who were given the task of starting to look at, 

if we were going to update EO–12333—which had not been updated since the IRTPA, which passed in 2004—how would you update it to recognize sort of these new roles, the new interfaces? 

Much of the executive order had not been updated at all for many, 

many years. So the missions of the various intelligence community 

elements. 

We went into it with an idea of making those updates, with the 

knowledge that we would make very few changes to Part 2 of the 

order, which dealt with the privacy and civil liberties protections, 

and we made very, very few changes to that. 

LAP51NQ082 with DISTILLER

17 

We then did what has worked so well in so many other instances. 

We got the leadership of the intelligence community together and 

said: Please take off your element hats and tell us what needs improving in this executive order for a more smoothly running intelligence community? 

We got those inputs and we started drafting. We spent a long 

time drafting the proposed language. It was very much like my 

prior experience in negotiating international agreements, quite 

frankly, by the time we worked our way through. But that was my 

main role and, quite frankly, it was most of what I did for approximately a year of my time at the ODNI. 

Senator RUBIO. The inspector generals serve an important role in 

our system in terms of the oversight and ensuring that safeguards 

are in place. It’s crucial that people be able to trust them. So if 

you’re confirmed, can you describe a little bit what you think the 

best way is to communicate to your workforce that the safeguards 

afforded to potential whistleblowers are such that any potential 

whistleblowers would feel comfortable reaching out to the Office of 

Inspector General? 

Ms. GIBSON. Senator, I think there’s two things that an inspector 

general or anyone can do in those sorts of circumstances. The first 

thing is you have to say it and you have to say it often, and you 

have to communicate it well and you have to make it so that people 

can come to you and feel like they are actually welcome to come 

to you. 

Then, once they come to you, you have to follow through appropriately: with an investigation if an investigation is warranted; if 

there are reprisals or threats of reprisals, by dealing with those 

promptly and effectively. That creates then a cycle that feeds on 

itself and that continues to encourage people to come forward. 

So it’s both the communication and the follow-through, which you 

hope will bring more communication. 

Senator RUBIO. You stated in your response to a prehearing 

question that there weren’t any challenges facing the NRO IG. 

However, from open press accounts from 2014 it appears there 

were significant cultural impediments to the independence of the 

Office of Inspector General. I’m looking at one article in particular, 

the 28th of October, regarding the deputy director of the National 

Reconnaissance Office. 

If you’re confirmed, how do you intend to maintain the independence of your office and that of your staff from some of the issues 

that have been outlined in those 2014 cases? 

Ms. GIBSON. Senator, I think if I were confirmed the fact that I 

am a Senate-confirmed IG would also add to my independence in 

that position. I think that was part of the reason for this being 

made a Senate-confirmed position. So I think that would help, to 

start with. 

I think that the office, from what I’ve seen—and I don’t have all 

the facts of those earlier allegations, but from what I’ve seen recently—they’ve already made great strides forward. They have a 

very strong personnel system that they run internal to the IG, so 

that others in the NRO can’t make personnel decisions that affect 

the office, but it’s the leadership of the IG’s office making those decisions. I think that’s important. 

LAP51NQ082 with DISTILLER

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I think it’s important for your people to know that if they’re feeling those sorts of pressures that they can come to you as the IG 

and bring those concerns to your attention so that you can deal effectively with them. I think oftentimes for an IG, much like for a 

general counsel, your role is to be that layer that protects your people from undue influence so that they can accomplish the job that 

they need to, and I would look to do much the same if I were confirmed as the IG. 

Chairman BURR. Senator King. 

Senator KING. Thank you, Mr. Chair. 

Ms. Gibson, who appointed you to this job? 

Ms. GIBSON. I have not been appointed yet, sir. 

Senator KING. Who nominated you for this job? 

Ms. GIBSON. President Obama nominated me. 

Senator KING. I think that’s a very important point. You weren’t 

nominated by the head of the NRO or the head of the IC. Everybody has said this, but I want to put a really fine point on it. You 

have one of the most important jobs in the United States Government, particularly because of the nature of the intelligence community, which is immune from much of the scrutiny of the public in 

many ways that the Department of Agriculture, the Department of 

the Interior is, with outside groups and lobbying groups and press 

and everything else. Therefore we have to have—it’s an IG-squared 

job in my view, that you have to be fiercely independent. 

I hope you will take that. You use one word in your testimony 

that made my ears prick up, which was ‘‘partner.’’ I don’t want you 

to be anybody’s partner over there. I want you to be—my high 

school football coach used to say he wanted us agile, mobile, and 

hostile. That’s where you have to do this, because this committee 

can’t function without a truly independent IG in these intelligence 

community agencies that is responsible to the President of the 

United States and to this Congress. 

Can you reassure me on this point? 

Ms. GIBSON. Sir, I can assure you that I’d do my very best. I believe that I would be independent. As you state, the nomination 

from the President, confirmation and appointment if I’m confirmed, 

would add to that independence. 

As I mentioned early on, I truly do expect this to be my swan 

song, so I don’t need to be anyone’s friend in order to accomplish 

this job and move on to another job when I finish. I’ve retired once 

already, from the Army, and I hope to not retire more than twice, 

and I hope to do it in the not too distant future. 

So I don’t foresee any problems with independence. I would certainly hope that if you saw any of those problems as the committees who would also help me oversee, that you would let me know 

that you were concerned about that, because I would see you as a 

partner in that, sir. 

Senator KING. That’s a partnership I approve of. Thank you. 

Let’s move on to the question of contracts. You talked about the 

limitations on staff and the fact that the NRO administers huge 

contracts, a lot of taxpayer dollars. How about a force multiplier 

called the GAO? Do you feel there’s a role for the GAO to monitor 

and assess some of these contracts, just as they do in exactly the 

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same kind of procurement situations in the Department of Defense? 

Ms. GIBSON. Sir, I believe there’s a role for the GAO. I know that 

we’ve worked out in the intelligence community a lot of that interface in recent years. I think it’s a role where you have to complement and coordinate. Otherwise you’re wasting resources, oversight resources. So I think it’s something that you would want to 

make sure that you found the appropriate balance. 

Senator KING. But you mentioned in your testimony you need 

auditors, you need engineers, you need people that are contract administrators. I assume you don’t have all of those resources and assets within your office? 

Ms. GIBSON. I do, sir. 

Senator KING. You have all of the resources to adequately assess 

billion-dollar contracts? 

Ms. GIBSON. From what I have been able to ascertain, I have a 

very qualified staff. If I am confirmed and I get in and I think I 

don’t have the resources I need, the statute does require that I 

come to the committees and request the resources that I think are 

appropriate. 

I think the one thing that the NRO IG’s Office has that is unique 

is it has the expertise and it has the understanding of the mission, 

and it does have technical expertise that doesn’t reside perhaps 

elsewhere in the oversight mechanisms. So I would hope that the 

committee would come to the NRO IG to look at these problems 

first, and if there were gaps in expertise that were needed, there 

are also ways to pull in other experts. 

So again, I think, as I said in my opening, much of oversight is 

a team sport. The important thing is to make sure that you’re putting the right player on the right problem. 

Senator KING. I would urge you to think about and learn about 

the capacities of the GAO. Senator Coburn and I sponsored an 

amendment a year ago that allowed the GAO for the first time to 

play a role in the intelligence community on facilities. 

I think we need to think further. Again, you’re talking about efficiency and resources. We’ve got an agency that is very capable of 

doing this function and I urge you to make that a part of your toolkit as you move forward in this position. 

Finally, I want to compliment you as well, and I’m delighted that 

you’re taking on this challenge. Given your experience both in the 

JAG Corps and at the IC, I think you’re the right person for the 

right job at the right time. But human nature being what it is, we 

all want to be friends and popular with our coworkers. You’ve got 

to be willing to be difficult and very aggressive, because again this 

is different from the IG of another agency. This is one where there 

aren’t that many people watching, and that puts a special responsibility, it seems to me, on the job of the IG within the IC. 

So I want to thank you and I look forward to working with you. 

Ms. GIBSON. Thank you, sir. 

Chairman BURR. Senator Hirono. 

Senator HIRONO. Thank you. 

Ms. Gibson, it’s good to see you again, and I can echo the comments of my colleagues to say that your job is particularly imporLAP51NQ082 with DISTILLER

20 

tant because you’re dealing with a community of actors for whom 

transparency is not necessarily their number one priority. 

So let me ask you this. I know that ODNI has been working in 

recent years to enhance public understanding about the intelligence community, its authorities and oversight of its activities 

and programs. The ODNI recognizes that increased transparency 

in the IC will help increase trust that Americans’ civil liberties are 

protected and that their taxpayer dollars are being well spent. 

What do you believe is the role of transparency in the Office of 

the NRO IG, and do you believe there is a way to create unclassified versions of reviews and audits and otherwise make the public 

more aware of the IG’s work than has been done in the past? 

Ms. GIBSON. Thank you, Senator. I will say to start that I’m a 

firm believer in transparency and have been fully behind the efforts at the ODNI to be more transparent. I agree that we can’t always be transparent about exactly what we are doing, but we 

should be more and more transparent about how we are doing it 

and what the oversight mechanisms are that are in place to make 

sure that the authorities that the intelligence community has are 

not abused. 

So, first, I’m a proponent of transparency. How many of the IG 

reports could be released I think would depend on the topic. I think 

I would look for the topics that can be made public. I know that 

they’ve published several of their reports in the past, and I would 

look to continue to do that. 

Also, we have worked quite a bit to figure out how to write 

things so that you separate the classified from the unclassified and 

not tangle it up to the extent that once you’ve redacted it that it’s 

hard to understand. So much of it comes with how you write the 

report and how you explain things. So I would look to continue 

those sorts of efforts that are in place and be more transparent 

wherever possible. 

Senator HIRONO. I think that kind of commitment is very necessary as you do your audits and write your reports, because, as 

you say, if you write it in a way where redacting therefore results 

in making no sense that does not help the public. 

In 2012 a former NRO IG was quoted in a news article saying 

that he wasn’t surprised by allegations against an NRO official regarding the handling of contracts. He noted that, and I quote, 

‘‘You’re talking about a lot of money at this agency and a culture 

within the intelligence community that isn’t really comfortable 

with the idea of transparency. Generally speaking, people in the 

agency are ethical, but there is a certain dependency on contractors 

and closeness with contractors that can create an awkward environment.’’ End quote. 

Do you consider closeness with contractors a problem with the 

NRO IG and, if so, how would you prevent or minimize this problem? 

Ms. GIBSON. Ma’am, I don’t have enough experience yet to say 

whether there’s a problem within the IG’s office with contractors. 

If you’re asking about the larger NRO, if confirmed it’s certainly 

something that any IG would have to keep a very close eye on at 

the NRO. 

LAP51NQ082 with DISTILLER

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Contractors play a very important role there. They’re essential to 

the mission. But at the same time, they are not government employees and you always have to keep in mind the idea of what is 

an inherently governmental function and what isn’t and who’s actually making the decisions, which is I think what’s really important when you talk about those inherently governmental functions. 

The people making the decisions should be government employees 

and not contractors. 

So I think it’s the sort of thing you would have to keep an eye 

on at all times. 

Senator HIRONO. Well, human nature being what it is, those who 

deal with—the government officials who deal with contractors on 

an ongoing basis—and there’s a lot of money at stake—I think that 

that kind of awkward closeness is particularly of concern. So that 

is an area that I would think that there should be enhanced scrutiny on your part, to make sure that these kinds of cozy relationships do not result in misuse of taxpayer money. 

Ms. GIBSON. I share your concern, ma’am, and I’ll make that a 

priority if I’m confirmed. 

Senator HIRONO. I have a few more questions, but I think I’ll 

stop here. Thank you, Mr. Chairman. 

Chairman BURR. Senator Blunt. 

Senator BLUNT. Thank you. Thank you, Chairman. Ms. Gibson, 

thanks for being here with us today. 

The NRO has its feet both in the Title 10 and the Title 50 world. 

In your statement for the record, you mention the growing risks 

that you believe are there for the NRO mission. I think a lot of people on this committee believe that better coordination between the 

space-related activities of the Defense Department and the intelligence community are needed. 

How do you see your office playing a role in improving the Title 

10 and Title 50 relationships? 

Ms. GIBSON. Sir, I see the main place where that relationship 

comes into play in the way that you’re talking about in the requirements process as programs are conceived and plans are built for 

those programs. So I think the oversight of the IG as those processes work their way through, because those processes are so crucial for both the Title 10 and the Title 50, which are very intertwined at NRO—it’s an agency that supports a broad, broad range 

of requirements. 

So I think oversight of that requirements process is probably 

where the IG could be most useful. But I would certainly look for 

other ways, if I were confirmed, to get at any other connective tissue that really needed a good shaking out and a good look. 

Senator BLUNT. Well, I’ll just repeat. I think several people on 

this committee think that steps in newer directions aren’t nearly 

as clear to us as they might otherwise be, and that would be a 

place where you could have a view of both departments, both the 

Title 10 and the Title 50 world, in ways that others don’t. 

You know, you discuss also in your statement your involvement 

in establishing the Office of the Director of National Intelligence 

when that was set up and drafting several of the directives involved in setting that up. There are broad efforts, obviously, to fosLAP51NQ082 with DISTILLER

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ter greater sharing of what’s acquired and integrating what we 

learn from that. 

What are some of the pitfalls you think face the NRO in accomplishing the tasks that were envisioned by the establishment of the 

DNI? 

Ms. GIBSON. Senator, I actually think the NRO was probably affected, but not perhaps affected as much as some of the other intelligence community elements, and in the ways that they were affected it’s ways that they have helped the change along. 

So one of the first couple of policies that I actually worked on 

when I started at the ODNI was the intelligence community directives on major system acquisitions. So this more flexible, spiral development process that was put in place for majority National Intelligence Program-funded major system acquisitions I think was 

something that the NRO supported, and so it was a cooperative 

process, if you will, and I think they put a lot of that in place. 

I’ve seen a great deal of cooperation. I’ve seen a lot of maturity 

in the processes, with the Systems and Resource Analysis Office 

and the maturity of the cost estimates that are happening and are 

getting better and better as we go along. Then I’m very, very encouraged actually also by the analysis that’s being done for—this 

is what you hoped to accomplish, these are the requirements you 

set in place, this is how you thought you would use it, and then 

to look at it on the back end and say, is that what happened, did 

you get what you thought you were going to get out of this? If not, 

why not? 

So this analysis that’s happening between the ODNI in partnership with the NRO and with DOD I think has helped it progress 

toward more effective and efficient acquisitions. I’m not saying that 

there isn’t still progress to be made. But I do think that they’re 

moving in a hopeful direction there, and if I was confirmed as the 

IG it’s something that I actually feel strongly about and would 

work diligently to continue improving. 

Senator BLUNT. Well, I would think that it’s a great place for the 

IG to do just exactly the kind of evaluation of what results are 

being produced versus the goals that were being set that you would 

have. And certainly your effort in establishing the DNI and working with that is clearly a great background for this job. 

Thank you, Mr. Chairman. 

Ms. GIBSON. Thank you, sir. 

Chairman BURR. Senator Cotton. 

Senator COTTON. Thank you. 

Ms. Gibson, thank you for appearing here today, and thank you 

for once again answering the call to service for our country. 

I want to associate myself with what Senator King, Senator 

Hirono, and Senator Blunt have said about the importance of the 

IG in the intelligence community in general and the NRO in particular because of the often secret nature of the work that you do. 

And, as Senator Blunt said, the NRO has a dual structure under 

both the military and the intelligence community. 

I am one of four members on this committee who also sits on the 

Armed Services Committee, the only Republican. I’d just like to get 

the same commitment that you gave to Senator King about this 

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committee of keeping the Armed Services Committee informed 

where appropriate as well. 

Ms. GIBSON. Absolutely, sir. 

Senator COTTON. Thank you. 

You’ve received some very stellar letters of recommendation from 

esteemed individuals, such as Chris Inglis and Bob Litt. They say 

that your character and integrity are of the highest caliber and beyond reproach. I think that’s evidenced by your up-front disclosure 

of a 1999 Army JAG professional responsibility inquiry, which I 

understand was dismissed as unfounded. 

Ms. GIBSON. Yes, sir. 

Senator COTTON. Could you simply explain a little bit more about 

that matter in your own words, for those who have not had a 

chance to review the thorough explanation of it in writing? 

Ms. GIBSON. Yes, sir. In the mid-1990s I was the Deputy Staff 

Judge Advocate at Aberdeen Proving Ground. While I was there— 

they actually sent me to Aberdeen, by the way, to get out of criminal law for a while. Aberdeen Proving Ground is where they try to 

break things and test things, and it tends to work on contracting 

instead of criminal law. 

So I was one of the few senior attorneys there who had much investigative or criminal law experience. While I was there, I was the 

primary legal advisor for the Ordnance Center and School, which 

had multiple allegations of sexual assault and sexual abuse of 

trainees by drill sergeants and instructors. It was a prolonged and 

very high-profile investigation. 

When the first round of courts martial were final months later, 

the Army Inspector General came in and did a thorough review. 

During that review there was an allegation made that I had inappropriately told investigators not to read rights to certain trainees, 

Article 31 rights, which are similar to Miranda but also have to include the crime that the person is suspected of. 

There was a full investigation of that. The Army Inspector General turned it over to the Army JAG Standards of Conduct Office. 

They conducted a very long and thorough investigation of that, and 

it was eventually dismissed as unfounded. 

Senator COTTON. Well, thank you for sharing that for us. I know 

it was a high-profile matter, and again I think it reflects very well 

on your character that you’ve disclosed it up front, as well as that 

it was dismissed as completely unfounded. And it’s also reflected in 

the fact that the Army continued to put you in positions of greater 

trust and responsibility, as the intelligence community has as well. 

Ms. GIBSON. Thank you, sir. 

Senator COTTON. One final question. I note from question 12 of 

your questionnaire that you are on the board of directors of the 

City of Fairfax Theatre Company and you are general counsel of 

Women in Technology. And in question 20 you say that you intend 

to resign both of those positions. 

Ms. GIBSON. Yes, sir. 

Senator COTTON. Is that required by law or regulation? 

Ms. GIBSON. It’s something that the Administration asks of its 

nominees and appointees if they’re confirmed, so that they can concentrate on the job at hand. 

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24 

Senator COTTON. Do you think being a volunteer member on a 

city theater company would distract you from your job? 

Ms. GIBSON. I intend to keep volunteering with the theater, sir, 

but not be on the board. 

Senator COTTON. Well, I understand that there are some positions outside our work that might conflict with our work, but 

maybe this committee should examine whether or not we need to 

require government employees to resign from volunteer positions 

like boards of directors of volunteer theater companies. I think it’s 

a good thing for government employees to be involved in their community. 

Ms. GIBSON. Thank you for your support, and I can get you tickets for ‘‘The Music Man’’ this summer. 

Senator BLUNT. He can’t accept them. 

[Laughter.] 

Senator COTTON. I can’t accept them probably, and probably the 

appreciation would be lost on me, I suspect. But thank you for 

again answering the call of service. 

Ms. GIBSON. Thank you, sir. 

Chairman BURR. I thank my colleagues. 

If nobody seeks other questions, let me share with members: It 

is the Vice Chairman’s and my intent to vote Ms. Gibson out of 

committee on Thursday. To our colleagues that are on Armed Services and to the one or two that are on Homeland Security, they also 

have a sequential process in this. The faster they can choose not 

to have a hearing, the faster we could get Ms. Gibson to the floor. 

It’s certainly my intent to try to get Ms. Gibson’s nomination in 

place as quickly as we can. So any help that you can be on other 

committees that have responsibilities, I’m grateful to you. 

With that, Ms. Gibson, thank you for your testimony today. 

Thank you for the sacrifices you’ve given, not only for the military, 

but in your career with government. We’re grateful to the sacrifices 

your family have made. And the last thing, if you would today, you 

thank your mother for us. 

Ms. GIBSON. I will, sir. 

Chairman BURR. This hearing’s adjourned. 

[Whereupon, at 3:33 p.m., the hearing was adjourned.] 

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Supplemental Material 

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June3,2016 

The Honorable Richard Burr 

Chainnan 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

The Honorable Dianne Feinstein 

Vice Chainnan 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

Benjamin A. Powell 

1875 Pennsylvania Ave., NW 

Washington, DC 20006 

Dear Chairman Burr and Vice Chairman Feinstein: 

I write to give ttiy strongest possible support to the nomination of Susan Gibson for 

Inspector General of the National Reconnaissance Office (NRO). 

Ms. Gibson has a highly distinguished public service record spanning three decades, from 

service around the world in the U.S. Army to her work in the Intelligence Community. She has 

devoted her life to the rule oflaw and our national security. She will bring to the position the 

experience, integrity, judgment, and intelligence necessary for such an important position. I 

have no doubt she will do an outstanding job. 

As the General Counsel to the first three Directors of National Intelligence, ~ worked with 

Ms. Gibson on a daily basis in her position as the Deputy General Counsel for Management in 

the Office of the Director ofNational Intelligence (ODNI). She was the person all of us in the 

General Counsel's office (and senior leaders in the ODNI) looked to for advice on the toughest 

issues. She was always willing to handle the most demanding assignments. She was also a . 

tremendous leader and mentor to everyone in the office and she performed every day at the 

highest level. Her leadership by example was something all of us learned from and sought to 

emulate. 

Ms. Gibson worked on many critical issues across agencies that required a 

comprehensive understanding of the missions, authorities, regulations, and operations of 

elements of the Intelligence Community- from fiscal and acquisition issues to personnel issues 

to operational issues. She was always fair and thorough in handling interagency issues. She is 

highly respected throughout the Community for her ability resolve difficult issues. 
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to operational issues. She was always fair and thorough in handling interagency issues. She is 

highly respected throughout the Community for her ability resolve difficult issues. 

Ms. Gibson has all the characteristics that will make a superb IG, including the highest 

level of integrity and trustworthiness, deep experience in virtually every facet of the operation of 

an intelligence agency, and an unwavering devotion to public service and the rule oflaw. 

The country is fortunate to have devoted public servants like Ms. Gibson. The country 

and the NRO will greatly benefit from her leadership of the NRO IG office. I urge the 

Committee in the strongest terms to recommend to the full Senate the approval of her 

nomination. 

Sincerely, 

Bef\iamin A. Powell 
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OFFICE OF THE UNDER SECRETARY OF DEFENSE 

4000 DEFENSE PENTAGON 

PE~LANO 

-

The Honorable Richard Burr 

Chairman 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

The Honorable Dianne Feinstein 

Vice Chairman 

Select Committee on Intelligence 

United States Senate 

Washington,DC 20510 

WASHINGTON, D.C. 20301-4000 

June 6, 2016 

Dear Chairman Burr and Vice Chairman Feinstein: 

I write to provide the strongest possible recommendation in support of the confinnation of 

Ms. Susan Gibson as Inspector General of the National Reconoaissance Office (NRO). 

I have known Susan Gibson for 20 years, during which she and I both served as active 

duty Judge Advocates in the U.S. Army, retired from the military and continued to serve as senior 

civilian attorneys in the federal sector, and were privileged to be selected to lead at the executive 

le'liel in our respective agencies. Our long-atanding professional association has been 

complemented by a close personal friendship with Susan, Tim, her husband of almost 36 years, 

and their two daughters, Kate and Joanna, both of whom I bave watched grow into happy, 

healthy, and confident young women, in major part due to the love, support. and strong values 

with which Susan and Tim approached parenting. 

I am certain that many will write to you lauding Susan's recent, decade-long service to the 

Office of the Director ofNational Intelligence and to the Intelligence Community writ large. 

Accordingly,l would like to focus my letter on two earlier periods in Susan's distinguished 

military career that, in my view, illustrate well her ability to serve with extraordinary competence 

and enduring integrity as the first presidentially-appointed, Senate-confirmed Inspector General 

oftheNRO. 

I first met Susan in 1996, in the context of the Aberdeen Proving Ground sexual assault 

scandal in which the Army brought charges against 12 commissioned and non-commissioned 

male officers for sexual assault on female trainees under their command. As the Deputy Staff 

Judge Advocate of the legal office on base, Susan was responsible for oversight of the extensive 

criminal investigation and complex prosecutions tbat resulted. In addition, she served as the 

principal command spokesperson on legal matters associated with the scandal. I was stationed in 

the Pentagon and worked with Susan on a daily basis in an effort to address the novel legal and 

policy issues that these cases brought to the fore. Even at this early stage of my career, I 
29 

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recognized in Susan a genius for the practice of criminal law and the management of high-profile 

cases. She proved herself to be persistently thorough, ensuring that investigators and prosecutors 

left "no stone unturned"; absolutely committed to the application of the rule oflaw in all matters; 

and possessed of unerringly sound judgment in the face of withering external pressure and public 

scrutiny. 

Susan and I next worked together closely from 2001-2003, during her assignment as the 

Staff Judge Advocate ofthe U.S. Army Criminal Investigation Command, in which capacity she 

provided legal and policy advice and oversight of criminal investigations deriving from the 

Army's global operations. Her work spanned the post 9-1 I , counter-terrorism investigations that 

laid the foundation for the ongoing Military Commission prosecutions of high-value detainees at 

Guantanamo Bay; investigations into widespread fraud in military contracting operations in 

Afghanistan and Iraq; and coordinating Department of Defense investigations of allegations that 

American soldiers engaged in the abuse of detainees at Abu Ghraib prison. Again, her 

performance was exemplary, setting the standard for legal analysis, fair dealing, and pragmatic 

problem solving, all grounded in her uncompromising personal and professional integrity. 

I would be remiss were I not to comment on Susan's leadership. Over the years, I have 

marveled at her seemingly innate ability to lead diverse and multi-disciplinary organizations, task 

forces, and steering groups-large and small-to mission success. She is an expert at building 

strong teams; routinely identifies and develops smart talent; and generally gets along with 

everyone, asking nothing from a subordinate that she would not herself undertake. I am certain 

that, if confirmed, she will bring this same level of competence, commitment, and caring, to her 

leadership of the people comprising the NRO Office of the Inspector General. 

Susan Gibson is an accomplished and dedicated professional, who I am honored and 

proud to have known as a colleague and friend. I could not be more certain that, if confirmed, she 

will serve the Intelligence Community, the Administration, the Congress, and our Nation, with 

consummate integrity, fairness, and dedication. 

Please do not hesitate to contact me by email at 

telephone at - should you require any additiOnal mtonnaltiOl1. 

or by 

Thank you for the opportunity to lend my strongest possible support to Ms. Gibson as you 

consider her nomination for confirmation. 

Very respectfully, 

Deputy Assistant Secretary of Defense 

for Manpower and Reserve Affairs, 

Performing the Duties of the Principal Deputy 

Under Secretary of Defense for Personnel and 

Readiness 

2 
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.... :;,l'.;f! ,-<.~~·i_~~/J>' 

lL:.::.Ul 

~.Q.lf ··~ 

The Mary M. and Robert Looker Distinguished Professor of Cyber Studies 

Leahy HaD 

The Honorable Richard Burr 

Chairman 

United States Naval Aeademy 

Annapolis, Maryland 21402 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

The Honorable Dianne Feinstein 

Vice Chairman 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

Dear Chairman Burr and Vice Chairman Feinstein: 

4June2016 

I write to provide my strongest possible recommendation for Susan Gibson as a 

candidate for the position of Inspector General of the National Reconnaissance Office (NRO). 

I first met Susan in 1991 when we served together on the faculty of the United States 

Military Academy in West Point, NY (West Point). Across the intervening years, her 

professional work, advice and counsel have been influential in my own work as a senior leader at 

the National Security Agency (NSA) where I was responsible for developing and sustaining 

policies that fully comport with the letter and spirit of the law in a complex and ever changing 

environment. While Susan's professional qualities are too numerous to fully explore in this 

letter I will focus my remarks on her service, integrity, and judgment. 

Serviee: Susan is without peer in the diversity, challenge and consequence of a career of 

public service that spans .a remarkable 30 years. Balancing the demands of career and family, 

she has excelled at virtually every level. Rising to the rank of full Colonel in the U.S. Army, she 

demonstrated superb abilities regarding the application of law across the breadth of military 

operations, criminal investigation, and the defense of individual rights ranging from privacy to 

expert counsel in administrative and criminal proceedings. As an associate professor of law at 

West Point, she invested in the professional education of an oncoming generation while 

advancing the foundation of the law that guides their careers in service to the Nation. As a 

senior civilian executive serving as the Deputy General Counsel for Management and Principal 

Deputy General Counsel for the Office of the Director of National Intelligence, she supervised 

27lawyers while providing expert counsel on some of the thorniest legal issues confronting the 

Nation. 
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Integrity: As the Deputy Director of the ~SA, I was especially privileged during the 

period of 2007-2013 to draw on Susan's rounsel on matters affecting the conduct of U.S. 

intelligence activities. She was unfailingly prompt, candid and baJaoced -always generating an 

answer that was on-point and devoid of any bias. Importantly, while Susan always produced an 

answer that was helpful and actionable, she never compromised its value by fi:aming her COUIJSel 

in terms influenced by preferences and biases favorable to her audience. The result V\>-as 

guidance that enabled accomplishment of the task at hand -in exactly the right way \'ltithout 

resort to contorted justifications or patchwork policy. 

Judgment: Susan's judgment bas been honed through many years and successively more 

demanding roles in which she served as the decision authority for difficult choices with longterm consequences. As an Army Captain, she inter\'iewed 100+ law students in New York and 

Delaware \\obo were applying to join the Army Judge Advocate General Corps, helping to select 

those \\ilo would serve long careers in service to the law. As a \Vest Point Associate Professor of 

Law, she developed and sustained an annual five-week course that prepared attorneys to become 

professors - 'teaching the teachers' \\obo provide an educational foundation in the law to all West 

Point graduates. No stranger to difficult situations, Susan sen•ed as the legal advisor to the twostar commander of the U.S. Army Ordnance School at Aberdeen Proving Grounds in 1996 as the 

command dealt with the legal, congressional, and public relations issues during the Drill 

Sergeant sexual assault investigations and rape prosecutions that gained natiooal media attention. 

Her steady hand and expert counsel ''-as material to the Army's ability to deliver justice to those 

involved, while preparing the Army to address the systemic issues underpinning them. 

Across my o"n career, I ha;-e met and worked \\ith thousands of public ser\'arltS in both 

military and ci\'ihan settings. Few people that I've had the privilege of working vvith have 

impressed me as much, or positi>-ely impacted my professional development, as Susan Gibson. 

Based on my 43 years of public sen'ice, including twenty-eight years at the National Security 

Agency, I am convinced that she is extremely well qualified to continue and expand her superb 

career of sen'ice as the Inspector General of the ::-m.o. Across her military and civilian career(s), 

I have observed the \'irtues of initiative, excellence, and extraordinary follow-through that are the 

hallmarks of exceptional sec> 'ice. Equally important, Susan Gibson possesses an enthusiastic and 

vigorous nature that inspires all those in her acquaintance to follow a similar course. I give her 

my highest possible recommendation. 

Sincerely, 

John C. ("Chris") Inglis 

Brigadier General, USAF (ret) 

Former Deputy Director, National Security Agency 

The CSNA Robert and Mary M. Looker Distinguished Professor of Cyber Studies 
32 

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OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE 

OFFICE OF GENERAL COUNSEL 

The Honorable Richard Burr 

Chairman 

Select Committee on Intelligence 

United States Senate 

The Honorable Dianne Feinstein 

Vice Chairman 

Select Committee on Intelligence 

United States Senate 

WASHINGTON, DC 20511 

Dear Chairman Burr and Vice Chairman Feinstein: 

Susan Gibson, who has served for the past four years as Principal Deputy General Counsel 

in my office, has been nominated to be Inspector General of the National Reconnaissance Office. 

Having worked with Susan for almost seven years, I believe that she is an exceptionally well 

qualified candidate in every respect and urge that she be confirmed -despite the loss that my 

office would suffer as a result. 

Susan's resume shows that her professional background and experience have prepared her 

well for the job of Inspector General. Her time as a military prosecutor allowed her to develop the 

investigative skills required. She has deep expertise and experience in federal fiscal, acquisition 

and procurement law, which are critical to any Inspector General's ability to fulfill the statutory 

mandate of preventing waste, fraud and abuse, but are particularly important in overseeing the 

NRO. Indeed, she has been the "go to" person for the Office of the Director of National 

Intelligence for those legal issues, and, if confirmed, would enter her position with a bead start in 

understanding NRO's vital mission and programs. As the Designated Agency Ethics Official 

(DAEO) for the ODNI, Susan has important experience in understanding and addressing ethical 

issues. In short, I believe that Susan's professional experience is ideal for the position for which 

she has been nominated. 

Susan's resume does not, however, reflect many other, equally important, traits that suit 

her for the job. First, she is an effective manager. As Principal Deputy General Counsel, Susan 

has functioned as a "Chief Operating Officer" for the Office of General Counsel, with primary 

responsibility for budget, personnel, and human resources issues. Under her leadership, OGC 

performed our mission effectively while maintaining excellent budget efficiency. She bas also 

mentored lawyers in our office, helping them to get rotatiooal assignments that further their 

professional development, and has worked hard to ensure that not only OGC, but all of ODNI has 

a diverse workforce. She is well-regarded by the entire office. I have no doubt that Susan would 

be equally effective at managing the personnel and resources of the NRO Office of Inspector General. 

She is equally well-regarded throughout ODNI and the Intelligence Community as a 

whole, for her collegial approach and her willingness to work constructively to resolve problems. 

Because of the nature of the authorities provided to the DNI in the Natidhal Security Act, 
33 

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The Honorable Richard Burr 

The Honorable Dianne Feinstein 

accomplishing the ODNI's mission requires constant engagement with colleagues across the 

government. Susan has always focused on what is best for the government and the Nation as a 

whole, rather than on parochial interests of the ODNI, and as a result has achieved remarkable 

results, most recently in helping to develop the legal framework around the Intelligence 

Community Information Technology Enterprise (IC ITE). 

On a personal level, Susan is an excellent colleague, with sound judgment, a keen intellect 

and excellent writing skills. She is completely nonpartisan in the performance of her duties, 

understanding how essential it is that the Intelligence Community carry out its mission free of any 

political influence. And as DARO, she has shown on numerous occa~ions that she has no 

hesitancy in candidly advising others, including her superiors, on what the law requires. 

Finally, Susan has always demonstrated a commitment to the importance of effective 

oversight of the Intelligence Community. Because intelligence activities must largely be 

conducted in secret, effective congressional oversight is critical to providing the public assurance 

that those activities are conducted lawfully and with an appropriate respect for privacy and civil 

liberties. During my tenure, Susan has always taken seriously the statutory requirement that 

intelligence agencies keep the oversight committees "fully and currently informed," and has 

consistently argued for full disclosure and cooperation with the committees. 

In short, I cannot imagine a person who is more qualified than Susan to be Inspector 

General of the NRO. I am confident that, if confirmed, she would perform her duties with 

complete integrity, and would do honor to the office and the Nation. Please feel free to contact me 

if you have any questions. 

Very truly yours, 
34 

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"'185 

UNITED STATES SENATE 
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SELECT COMMITTEE ON INTELUGENCE 

UNITED STATES SENATE 

QUESTIONNAIRE FOR COMPLETION BY 

PRESIDENTIAL NOMINEES 

PABTA ·BIOGRAPHICAL INFOBMATION 

1. FUll. NAME: Sll811Il Sandner Gibson 

OTHER NAMES USED: Sll811Il Lynn Sindner 

2. DATB~PLACBOFBIRTII: Apri.ll7,1959;Alton,lllinois 

crrJZENSHlP: USA 

3. MARITAL STATUS: Married 

4. SPOUSE'S NAME: Timothy J. Gibson 

. S. SPOUSE'S MAIDEN NAME IF APPLICABLE: n/a 

6. NAMES AND AGES OF CHJLDREN: 

7. 

-

EDUCATIONSINCBffiGHSCHOOL: 

INS1Tl1JT[ON DATES ATI'ENPED 

MOIIItiOIIIh Colkge, Illinois 08/lm - 11/1980 

Setatle University 08/1982- 12/1984 

School of Law 

U.S. Army ludBe Advocate 08/1994- OS/1995 

General's School 

Uniwmity of Virginia 08/1997- OS/1998 

School of Law 

Mm 

• • 

DEGREE RECBiyED 

B.A. 

Geology&; Business 

JD. 

IL.M. 

Military Law 

IL.M. 

National Security Law 

DATBOFDBGRBB 

OS/1981 

12/1984 

OS/1995 

OS/1998 
36 

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8. EMPLOYMBNT RBCORD (LIST AIL POSITIONS HELD SINCB COUBGB, INCLUDlNG 

MILITARY SERVICE. INDICATE NAME OP EMPLOYER. POSll'ION, Til'LB OR 

DBSCRIPTION, LOCATION, AND DATES OFBMPLOYMBNT). 

EMPLOYER. POSITIONITITLE LOCATION DATES 

Office of the Director of PriJ!cipal Deputy General Mclean, Vtrginia Apr 12-present 

NatiOIIIIl Inmlligellce Counsel 

(OD:Nl) 

Office of the Director of DepUty Oenerlll Counsel McLean., VirgiDia Feb 07-Apr 12 

NatiOIIIIl Intelligence for Managtme~~t 

Defeusc Intelligence Seoiol' Associa1e General McLean., Virginia Aug OS- Feb 07 

Agea;;y - Detailed 10. Counsel (ColoDel) &:Bolling"Air 

ODNI Force Base 

Defeusc lntelHgeuce Assistant General Counsel C1arendcm, Virginia July 03-July 05 

A&er»:Y· (Colonel) 

Army Criminal . Staff Judge Advocale Ft. Belvoir, July 01-July 03 

I!Ivestigation Command (Lieu1eoant Colonel) Virginia 

u.s. Pacific Command Assistant Judge Advocale Camp Smith, June 98 -July 01 

(I.Jeulenant Colonel) Hawaii 

U.S. Army u..M. Student Uni~tyof July '17 -June 98 

(MIYor) Vtrginia 

Aberdeen Proving Ground 'Deputy Staff Judge Aberdeen P.iov:ing I June9S-June'l7 

Advocale (Major) Ground. Maryland 

Army Judge Advocate lL.M. Student (MIYor} CharlolresYille, July 94-June 95 

Genenl's School Vtrginia 

Army Trial Defeusc Senior Defense Counsel Seeul, Korea June92-June94 

Service (MIYor) 

u.s. Military Academy Professor (Captain) West Point, New Jljly 89-June 92 

York 

Pt. Leavenworth Trial Counsel &: Special Kansas June 8S -June 89 

Assistant us Attorney 

(Captain) 

Hancock Fabrics· Fabric Cutler&: Clerk Columbus, Georgia 1~82-June82 

Independent Contractor Costume Shop Pt.ltnox, Kentucky 1981 (various dales) Pt. Knox Dinner Theatre (design&: constr:uclion) 
37 

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9. GOVERNMENT EXPERIBNCE (JNDICATBEXPBRIBNCE IN OR ASSOCIATION WITH 

FEDERAL, STATE. OR LOCAL OOVBRNMBNTS, INCLUDING ADVISORY, 

CONSULTATIVB. HONORARY, OR OTHER PART-TIMB SBRVICE OR POS!I'ION. DO NOT 

RBPBAT INFORMATION ALREADY PROVIDED IN QUESTION 8). 

An governmeot experience is liated above. 

10. INDICATE ANY SPECTAL1ZBD lNTBILIGBNCE ORNATIONALSBCURITYBXPERTJSB 

YOU HA VB ACQUIRED HAVING SERVED IN Tim POSmONS DESCRIBED IN QUESTIONS 

8ANDIOR9. 

The majority of my 30-plus year cmeer bas been in the national security field, ·with the last IS years 

largely concentrated on intelligence aspects of national security. In lllldition, my graduate legal studies 

focused on illfemational and national security law. 

My militaiy legal practice included in-depth work on international agreements; domestic and 

international crisis response, law of armed conflict, infOrmation sbariug, privacy and civil h"benies, rule of 

law, and support to contingency operations. At DIA, I provided legal advice tegarding HUM1NT 

Operations, MASINT research and development (R&D), and international agreements; and taught classes 

for Reports Officers and Defense A.l:tacMs. At the ODNI, I helped stand up a new agency and provided 

legal support for virtually evecy aspect of the DNI' s mission, to include addmasing many issues of first 

impression regm:diug the applicati.on of the Intelligence Reform and Terrorism Prevention Act of 2004 

(IRTPA) and assisting with drafting mnltiple Intelligence Community Directives and l1llated policies. In 

2008, I was a member of the small team· that drafted and cooniinated the amendments to Bxecntive Order 

12333. Throughout my time at the ODNI, I have provided legal advice and connsel regarding . 

infOrmation sharing; privacy and civil liberties; congressional and legislative affairs; Iiuelligence 

Commnnity policies; the DNI's authorities nnder the IRTPA; the National Intelligence Program (NIP) 

budget proce:ss; fiscsl and appropriations law; oversight of intelligence operations; NIP-funded major 

system acquisitions, and advanced R&D. 

I have also provided advice and counsel as the ODNI worked through conntless isaues of shared 

authorities between and among the seventeen Intelligence Community elements, which reside in six 

Cabinet-level departments and two independent agencies. 

11. HONORS AND AWARDS (PR.OV)DBJNFORMATIONON SCHOLARSHIPS, FBU.OWSHIPS, 

HONORARYDEGRBES, MILITARY DECORATIONS, CIVnJAN SERVICE CITATIONS, OR 

ANY OTHER SPECIAL RECOGNlTION FOR OUTSTANDING PBRFORMANCE OR 

ACHIBVEMENT). 

· • Intelligence Commnni.ty Meritorious Presidential Rank Award- 2015 

• Militm:y awards: the Defense Snperior Service Medal, the Legion of Merit (2 awards), the Joint 

Meritorions Service Medal, the Merltorions Service Medal (3 Awards), the Army Commendation 

Med&J, and the Army Achievement Medal. . 

• Dommer Award for Outstanding Academic Achievement in Operational Law, May 1995 

•· Monmouth College Yonng Alnmnua Award, May 1995 

• Jndge Advocate Association Outstanding Career Armed Services Attorney, May 1994 

• Fcdcrai Bar Association Yonnger Fedentl Lawyer Awlltd, Sepfember 1993 

• Boldt Scholarship, University of Pnget Sound School of Law (now Seattle University) 

• Mortar Board Senior Honor Society, Monmonth College Chapter 
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12 ORGANJZATIONAL AFFILIATIONS (LIST MEMBERSHIPS IN AND OFFICES HBLD wmnN 

11lE LAST TEN YEARS IN ANY PROFESSIONAL, CIVIC, FRATERNAL, BUSINESS, 

SCHOLARLY, CULTURAL, CHARITABLE, OR OTHER SJMILAR ORGANIZATIONS). 

QRQAN1ZA11QN QffietiHELD ~ 

District of Columbia Bar Member 2008 -present 

W~StateBar Member 1985 -present 

(inaclive since 2009) 

Virginia State Bar Member (practice limited lo 2015- present 

ccn:porate counsel for WIT) 

Women in Technology (WIT) General Co1111Sel. to the Board 2015 -present 

(volunteer) 

City .of Fairfax 1'b.catre Company Member, Board~ Directors 2015 - pieSCnt 

(volunteer) 

Shakespeare Theatre Company Ambassador 2011 -present 

(volunteer) 

National Association, Daughters of 

the American Revolntion 

Member 2011-present 

Kappa Delta Sorority Member 1977-present 

(alumna since 1980) 

13. PUBUSHED WRITINGS AND SPEECHES (LIST THB TlTLES, PUBUSHERS, BLOGS AND 

PUBUCATi:ON DATES OF ANY BOO:KS, ARTICLES, REPORTS, OR OTHBRPUBIJSHED 

MATERIALS YOU HAVE AUTIIORBD. ALSO UST ANY PUBUC SPEECHES OR 

REMARKS YOU HAVE MADE WITHIN nm LAST TEN YEARS FOR WffiCHTHERE IS A 

TEXT, TRANSCRIPT, OR VIDEO). IF ASKED, WilL YOU PROVIDE A COPY OF EACH 

REQUESTED PUBUCATION, TEXT, TRANSCRIPT, OR VIDEO? 

PublicatjQ!!! 

• International Economic Sanctions: 11le Importance of Government Strucmres, 

13 Emory Intcmational Law Review, 161 (1999) 

• 11le Misplaced Reliance on Free and Fair Elections in Nation Building: 11le Rolt~ of 

CQnstitutional Democracy a1id the Rule of Law, 21 Honston Journal of Intcmational Law 1 

(1998) 

• lDclc of Extraterritorial Jurisdiction· Over Civilians: A New Look at an Old Problem, 148 

Military Law Review 114 (1995) 

• Conducting Courts-Martial Rehearings, The Army Lawyer, December 1991 
39 

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I will provide oopies of my publications if reques1ed. 

~ 

i have spo1am on or moderall:d several pa!l8la during the past few years, but have given no prepared 

romarks. To my knowledge, none of my appearances have been recorded or traDIIcribed. 

PABTB -OUALWJQTION§ 

14. QU.AI.JiliCA.TIONS (DESCRIBE WHY YOU BBLIBVB YOU ARB QUAIJFIBD TO SERVBAS 

THBINSPBCTOR GBNBRAL OFTHBNATIONAL RBCONNAISSANCB OFPICB). 

I believe that my broad exPerience in the llttelli.gence Community and the Department of Defense, 

including my legal and policy experience in national secorlty Jaw, acquisiti.o.., approprlati0111law, fiscal 

COIIb.'ols, criminal inWJStigafions, criminal prosecution and defense. big data and privacy, and related 

fields give me a strong substantive background to be the Inspector General of the National 

:Reconnaissance Office. In addilion, over the course of my career, I have rlaen from being a military 

proseclllm', to building. developing and UlllllllgiDg high-performing. high-morale IB8ms of profesaiOIIIIla. 

During my nearly eleven years at ODNI I have abo leamed.the value of, and bclped advance, inte1ligenc:e 

inlegration and bJt.eHgency coordination and coopenition. I would apply all of these expeliellces, it' 

CODfiimed as the NR,O Inspector Gena1ll, in my continued aemce to the nation. 

PARI C ·POLITICAL AND FOUIGN AFfiLIATIONS 

lS. POLil'ICAL ACT.IVlTIBS (l1ST ANYMBMBBRSHIPS OR OFFICES HELD IN OR 

FINANCIAL CONTRlBUTIONS OR SERVICES RBNDBRBD TO, ANY POLITICAL PARTY, 

BLBCTION COMMfiTBB, POLITICAL ACTION COMMriTBB, OR INDIVIDUAL 

CANDIDATE DORING THE LAST TBN YEARS). 

None 

16. CANDIDACY FOR PUBLIC OFFICE (FURNISH DETAILS OF ANY CANDIDACY FOR 

BLEcriVB PUBLIC OFFICE). 

None 

17. FORBIGN AFFILIATIONS 

(NOTB: QUESTIONS 17A AND B ARBNOTI.JMlT.fiD TO RELATIONSHIPS REQUIRING 

RBGISTRATION UNDER THB FOREIGN AGENTS RBGJSTRATION Ac:r. QUESTIONS 17A. B, 

AND C DO NOT CAIL FORA POSII'IVE RESPONSE IFTHB REPRESENTATION OR 

TRANSACTION WAS AUTHORIZBD BY THB UNITBD STATES OOVBRNMBNT IN 

CONNBCTIONWITH YOUR OR YOUR SPOUSE'S EMPLOYMENT IN OOVBRNMBNT 

SERVICE.) 
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A. HA VB YOU OR YOUR SPOUSBBVBR RBPRBSBNTBD IN ANY CAPAcrrY (E.G. 

BMPLOYBB, AT!ORNBY, OR POUI'ICALIBUSINBSS CONSULTANT), WITH OR WITHOUT 

COMPBNSATION, A FOREIGN GOVERNMENT OR AN ENTITY CONTROLLBD BYA 

FOREIGN OOVERNMBNTl IF SO, PLBASE FUlLY DESCRIBE SUCHRBLATIONSHIP. 

No 

B. HA VB ANY OF YOUR OR YOUR SPOUSE'S ASSOCIATES RBPRBSBNTBD, IN ANY 

CAPAcrrY, WITH OR WITHOUT COMPENSATION, A FOREIGN OOVERNMBNT ORAN 

ENTITY CONTROlLED BY A FOREIGN GOVBRNMBNT'l IF SO, PLBASB FUlLY 

DBSCR1BB SUCH RELATIONSHIP. 

Not to my knowledge. 

C. DURING THE PAST TEN YBARS, HA VB YOU OR YOUR SPOUSB RBCB1VBD ANY 

COMPENSATION PROM, OR BBBNINVOLVBD IN ANY FINANCIAL ORBUSJNBss 

TRANSACI'IONS wrm, A FOREIGN OOVBRNMBNT OR ANY ENTITY CoNTROLLBD BY 

AFORBION OOVBRNMBNT? IF SO, PLBASB PROVIDE DETAILS. 

No 

D. HA VB YOU OR YOUR SPOUSB EVER RBGISTBRBD UNDBR THE FOREIGN AGENTS 

.REGisTRATION Acr? IF SO, PLBASB PROVIDE DETAILS: 

No 

18. DESCRIBE ANY LOBBYING ACl'IVlTYDURING THE PAST TEN YEARS, OTHER THAN IN 

AN OFFICIAL U.S. OOVBRNMBNT CAPAcrrY, IN WinCH YOU OR YOUR SPOUSB HAVB 

BNGAGBD FOR THE PURPOSB OF DIRBCTLY OR INDIRBCTLY INFLUENCING THE 

PASSAGE, DBFBAT, OR MODIFICATION OFFBDBRAL LEGISLATION, OR FOR THE 

PURPOSE OF APFBCl'ING THE ADMINlSTRATION AND BXBCUTION OF FEDERAL LAW 

ORPUBUCPOUCY. 

None 
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pW D ·FINANCIAL DISCLOSURE AND CONFLJCI OF JNDRW 

19. DESCRIBE ANY EMPLOYMENT, BUSINESS RELATIONSHIP, FINANCIAL 

TRANSACTION, INVESTMENT, ASSOCIATION, OR ACIIVITY (]NCLUDING, BUT NOT 

L1MITBD TO, DEALINGS WITH THE FEDERAL GOVERNMENT ON YOUR OWN BEHALF 

OR ON BEHALF OF A CLIEN'l), WIDCH COULD CREATE, OR APPEAR TO CREATE, A 

CONFUCl' OF INTEREST IN THE POSmON TO WinCH YOU HA VB BEEN NOMINATED. 

None personally. My non-profit board positions have the potential to create a "Iepresentation back 

to the government" conflict of interest; however, if confirmed, I will resign from my board positions. 

Any potential conflicts of interest from my investments or from my spouse's investments, employment, 

and business relationships are outlined on my OGE-278. 

20. DO YOU INTEND TO SEVER AIL BUSINESS CONNECTIONS WITH YOUR PRESENT 

EMPLOYERS, FIRMS, BUSINESS ASSOCIATES AND/OR PARTNERSHIPS, OR OTHER 

ORGANIZATIONS IN THE EVENI' THAT YOU ARE CONFIRMED BY THE SENATE? IF 

NOT, PLEASE EXPLAIN. 

If confirmed, I plan to resign from my positions with the City of Fairfax Theatre Company and 

Women in Technology. 

21. DESCRIBE THE FINANCIAL ARRANGEMENTS YOU HA VB MADE OR PLAN TO MAKE, IF 

YOU ARE CONFIRMED, IN CONNECTION WITH SEVERANCE FROM YOUR CURRENT 

POSmON. PLEASE INCLUDE SEVERANCE PAY, PENSION RIGHTS, STOCK OPTIONS, 

DEFERRED INCOME ARRANGEMENTS, AND ANY AND AIL COMPENSATION THAT 

WllL OR MIGHT BE RECEIVED IN THE FUTURE AS A RESULT OF YOUR CURRENT 

BUSINESS OR PROFESSIONAL RELATIONSHIPS. 

N/A 

22. DO YOU HA VB ANY PLANS, COMMITMENTS, OR AGREEMENTS TO PURSUE OUTSIDE 

EMPLOYMENT, WITH OR WITHOUT COMPENSATION, DURING YOUR SERVICE WITH 

THE GOVERNMENT? IF SO, PLEASE PROVIDE DETAll..S. 

No 

23. AS FAR AS CAN BE FORESEEN, STATE YOUR PLANS AFTER COMPLETING 

GOVERNMENT SERVICE. PLEASE SPECIFICAIL Y DESCRIBE ANY AGREEMENTS OR 

UNDERSTANDINGS, WRITTEN OR UNWRITTEN, CONCERNING EMPLOYMENT AFTER 

LEAVING GOVERNMENT SERVICE. IN PARTICULAR, DESCRIBE ANY AGREEMENTS, 

UNDERSTANDINGS, OR OPTIONS TO RETilRN TO YOUR CURRENT POSmON. 

I plan to retire once I leave government I have no agreements or understandings. 
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24. IF YOU ARE PRESBNTLY IN OOVERNMBNT SERVICB, DURING THE PAST FIVE YEARS 

OF SUCH SERVICH, HA VB YOURECBIVBD FROM A PERSON OUfSlDE OF 

OOVERNMBNT AN OFFER OR EXPRESSION OF INTEREST TO EMPLOY YOUR 

SERVICES AF'rim. YOU.LEAVB GOVERNMENT SER.YJCE? IF YES, PLBASEPROVIDE 

DETAILS. 

No. I have received "cold calls" from nlCI:Ui.tm'S, which I turned down. 

25. IS YOUR SPOUSE EMPLOYED? IFY.ES AND THE NATURE OF THIS EMPLOYMENT IS 

RELATED IN ANYWAYTOTHEPOSmONFOR WinCH YOU ARE SEBKJNO 

CONFIRMATION,PLBASEINDICATEYOURSPOUSE'SEMPLOYER, THEPOSn'ION,AND 

THE LENGTH OFTIMB THBPOSlTIONHAS BEBN HElD. IF YOUR SPOUSE'S 

EMPLOYMBNTIS NOT RELATED TO THE POSnlONTo WHICH YOU HA VB BEBN 

NOMINATED, PLEASE SO STATE. 

~y spouse bas a Ph.D in Compotec Science and QWDB Parasang Solutions L.L.C., which provides 

S«Vices pdmarlly to amall cybet -u:chnology companies. His work is not related to the position for which 

I am seeking confirmation, &ut if any conflict or potential.conflict of in1enlat should arise, I will not 

participale penoually and substantially in any particular lllliUer that to my knOwledge bas a direct and 

pn:dictablo effect on the fioancial intl::rests of Pa:rasang Solutions L.L.C., unless I tint obtain a writllm 

~ 

waiver,J111l'8111111tto 1~ U.S.C. § 208(bX1). 1., will notparticipelll pencmally and substantially in any 

maae.r involving specific parties in whi!Jh I know a client ofParasang Solutions, L.L.C.is a 

party or represent~~ a party,·untess I am first lltlthori7m to participate, pursuant to S c.F.R. § 263S.502(d). 

26. LIST BELOW ALL CORPORATIONS,PARTNERSHJPS, FOUNDATIONS, TRUSTS, OR 

OTHEREN'lTI'.IES TOWARD WinCH YOU OR YOUR SPOUSE HAVE FIDUCIARY 

OBUOATIONS OR IN WHICH YOU OR YOUR SPOUSE HA VB HElD DIRECTORSHIPS OR 

OTHER POSITIONS OF TRUST DURING THE PAST FIVE YEARS. 

As listed in my le8pOlllle to question 12, I am on the board of dimctora for the Gzy of Fairfax 

Theatre Company and the General Counsel to the board ofWomenin Technology. My husband and I are 

ttustees and co-trust.ees for our moc:abJe living trllStS, which are part of our esta1e plan. I have held 110 

other outside positions in the past five years. 

In addition to the obligations and positions 1iS12d for my husband on my OOE-278, during the past 

five years my husband was also the Odef Scientist for Cyt. Systems at Draper Laboratory (tbrough JUDe 

2014). 

27. LIST ALL OJFl"S BXcEBDINO $100 IN V AI.Uij RBCBlVBD DtlRINO THE PAST FIVE 

YEARS BY YOU, YOUR SPOUSB, OR YO~ DEPENDENTS. (NOTE: OJFl"S RBCBlVBD 

FROM RELATIVES AND OIFI'S OlVEN TO YOUR SPOUSE OR DEPENDENT NBED NCY.r BE 

INCLUDED UNUlSS THB OJFTWAS OlVENwrrH YOUR KNOWLEDGE AND 

ACQUIBSCBNCBAND YOU HAD REASON TO BELIBVE THE GIFI' WAS 01VEN BECAUSE 

OF YOUR OFFICIAL POSITION.) 

Atlmdance at lNSA Baker Award Dinners in 2013 and 2015 (for myself and my husband). 
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28. LIST ALL SECURITIES, REAL PROPERTY, PARTNERSHIP JNTBRESTS, OR OTHER 

INVESTMENTS OR RECEIVABLES WITH A CURRENT MARKET V ALUB (OR, IF MARKET 

VALUE IS NOT ASCERTAINABLE. ESTIMATED CURRENT FAIR V ALUB) IN EXCESS OF 

$1,000. (NOTE: THE INFORMATION PROVIDED IN RESPONSE TO SCHEDULE A OF THE 

DISCLOSURE FORMS OF THE OFFICE OF GOVERNMENT ETIIICS MAY BE 

INCORPORATED BY REFERENCE, PROVIDED THAT CURRENT VALUATIONS ARE 

USED.) 

Please see my OGE-278, which was completed using current valuations. 

29. LIST ALL LOANS OR OTHER INDEBTEDNESS (INCLUDING ANY CONTINGENT 

LIABn.ITIES) IN EXCESS OF $10,000. EXCLUDE A MORTGAGE ON YOUR PERSONAL 

RESIDENCE UNLESS IT IS RENTED OUT, AND LOANS SECURED BY AUTOMOBILES, 

HOUSEHOLD FURNITURE, OR APPLIANCES. (NOTE: THE INFORMATION PROVIDED 

IN RESPONSE TO SCHEDULE C OF THE DISCLOSURE FORM OF THE OFFICE OF 

GOVERNMENT ETIIICS MAY BE INCORPORATED BY REFERENCE, PROVIDED THAT 

CONTINGENT UABn.ITIES ARE ALSO INCLUDED.) 

Please see my OGE-278. Contingent liabilities are included. 

30. ARE YOU OR YOUR SPOUSE NOW IN DEFAULT ON ANY LOAN, DEBT, OR OTHER 

FINANCIAL OBLIGATION? HAVE YOU OR YOUR SPOUSE BEEN IN DEFAULT ON ANY 

LOAN, DEBT, OR OTHER FINANCIAL OBLIGATION IN THE PAST TEN YEARS? HAVE 

YOU OR YOUR SPOUSE EVER BEEN REFUSED CREDIT OR HAD A LOAN APPLICATION 

DENIED? IF THE ANSWER TO ANY OF THESE QUESTIONS IS YES, PLEASE PROVIDE 

DETAILS. 

No 

31. LIST THE SPECIFIC SOURCES AND AMOUNTS OF ALL INCOME RECEIVBD DURING 

THE LAST FIVE YEARS, INCLUDING ALL SALARIES, FEES, DIVIDENDS, INTEREST, 

GIFTS, RENTS, ROYALTIES, PATENTS, HONORARIA, AND OTIIER ITEMS EXCEEDING 

$200. (COPIES OF U.S. INCOME TAX RETURNS FOR THESE YEARS MAY BE 

SUBSTITUTED HERE, BUT THEIR SUBMISSION IS NOT REQUIRED.) 
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32. IF ASKED, WDL YOU PROVIDE THE COMMITI'EE WITH COPIES OF YOUR AND YOUR 

SPOUSE'S FEDERAL INCOME TAX RETURNS FOR THE PAST THREE YEARS? 

Yes 

33. LIST AIL JURISDICTIONS 1NWIDCH YOU AND.YOUR SPOUSBF1LE ANNUAL INCOME 

TAX RETURNS. 

Federal 

Commonwealth of Virginia (City of Fairfax) 

34. HAVE YOUR FEDERAL OR STATE TAX RETURNS BEEN THE SUBJECI' OF AN AUDIT, 

INVESTIGATION,·ORINQUIRY AT ANY TIME? IF SO, PLEASE PROVIDE DETAILS, 

'INCLUDING THE RESULT OF ANY SUCH PROCBEDING. 

No 

3S. IF YOU ARE AN A'ITORNEY, ACCOUNTANT, OR OTHER PROFESSIONAL, PLEASE LIST 

AIL CLIENTS AND CUSTOMERS WHOM YOU BlLI..BD MORE THAN $200 WORTH OF 

SERVICES DURING THE PAST FIVE YEARS. ALSO, LIST AIL JURISDICTIONS IN WinCH 

YOU AREUCENSED TO PRACTICE. 

I have not billed any clients or customers. 

I am licensed to practice law in the District of Columbia; in Washington State (inactive); and in the 

Commonwealth of Virginia (Practice limited to corporate COlliiSel for Women in Technology). 
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36. DO YOU INTEND TO PLACE YOUR P1NANCIAL HOLDJNGS AND THOSE OF YOUR 

SPOUSE AND DBPBNDBNT MEMBERS OFYOURJMMIIDIATB HOUSEHOLD lN A BLIND 

'!'RUST? IF YES, PLBASBFURNJSHDEI'AJLS. IFNO, DESCRIBB QTHBR 

ARRANGEMBNTS FOR AVOIDJNG ANY POTENTIAL CONFLICI'S OF lNT.BREST. 

I do not intt:nd to place any of my or my spouse's fiuancial holdings in a blind trust. If an actual cr 

apparent conflict of inbRat should arise, I will consult with the I>esignaUid Agency Bthica Official and 

lllh appropriate steps to mitigate or eliminate any actual or apparent conflict of interest. 

37. lF APPLICABLB. IJSTTHB.LASTTBRBB YEARS OF ANNUAL FINANCIAL DISCLOSURE 

REPORTS YOU HA VB BBBN RBQUJRBD TO FlLB WITH YOUR AGENCY, DEPARTMENT, 

OR BRANCH OF GOVERNMENT. IF ASKED, WilL YOU PROVIDE A COPY OF THBSB 

REPORTS? 

I have filed an llllllll8l OOB-278 for the last three years, I will provide copies if requested. 

PART E· ETBICALMATl'ERS 

38. HA VB YOU BVBRBBBN THB SUB.JEcr OF A DISCIPLINARY PROCEBDJNG OR CIT.ED 

FORA BREACH OFBTHICS.OR UNPROFESSIONAL CO!'IDucr BY, OR BEEN THB 

SUBJBCT OF A COMPLAINT TO, ANY COURT, ADMINISTRATIVBAGBNCY, 

PROFBSSIONAL ASSOCIATION, DISClPLlNARY COMMrl'TBB, OR QTHBR 

PROFESSIONAL OROUP? IF SO, PLEASE PROVIDE DEI'AJLS. 

In 1999 I was the subject of a Professional Responsibility inquiry by the Army JAG Corps' Standards 

of Conduct Oft'K:e. The inquiry was closed as md'onuded. 

39. HA VB YOUBVBRBBBN lNVBSTIOATBD, HELD, ARRESTED, OR CHARGED BY ANY 

FEDERAL, STATE, OR OTIIBRLAW BNFORCBMBNr AUTHORITY FOR VIOLATION OF 

ANYFBDBRALSTATB,COUNTY,ORMUNICIPALLAW,RBGULATION,ORORDlNANCB, 

OTHER THAN A MINOR TRAFFIC OFFBNSB, OR NAMBD AS ADEfiBNDANT OR 

OTHERWISE IN ANY lNDICI'MBNT O:Q. INFORMATION RBLATJNG TO SUCH 

VIOLATION? IF SO, PLEASE PROVIDE DEI'An.S. 

No 

40. HAVE YOUBVBR BBBN CONVICTED OFOR BNTBRBD A PLEA OF GUILTY OR NOLO 

CONTENDERE TO ANY CRIMINAL VIOLATION OTimR THAN A MINOR TRAFFIC 

OFFENSE? IF SO, PLEASE PROVIDE DEI'AJLS. 

No 
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41. ARB YOUPRBSHNTLY OR HAVE YOUBVBRBEHN A PARTY IN INTEREST IN ANY 

ADMINISTRATIVE AGENCY PROCEEDING OR CIVIL LITIGATION? IF SO, PLBASB 

PROVIDE DETAILS. 

I am not a party in interest to any administrative proceedings; however, I was named aa one ai 

several responding TllliDRgement officials in an BBO matter tbat was inveStigated by the ODNI' s Office ai 

BBO and Diversity. The EBO allegations &gllinst me arose from advice I gave within the scope ai my 

responsibilities ss the Deputy General Counsel in connection with an ODNI internal review and personnel 

action involving the complainant. Complainant appealed the asencY' s ultimate findings and personnel 

actions taken against her, and she alleged the findinp and actions were discriminatory. I fully coopetall!d 

with the inll!mal EBO investigation. The ODNI comploted the EBO investigation ai the allegations and 

the complainant reqnested a hearing before the EEOC in January 2016. The case is awaiting assignment 

to an administrative judge for acljudication on the merilll. The named party to.tbis case is the Director ai 

National Intelligence, in bis ofl:icial capacity. 

42. HAVE YOU BEHN.INTERVIBWBD OR ASKED TO suPPLY ANY INFORMATION AS A 

WITNESS OR OTHERWISE IN CONNBCTIONWITHANY CONCJRBssiONAL 

INVESnGATION, FEDERAL, OR STATE AGBNCYPROCEEDING, GRAND JURY 

INVBSTIGATION, OR CRIMINAL OR CIVIL LITIGATION IN THE PAST TEN YEARS? IF 

SO, PLEASBPROVIDEDETAILS. 

I provided a sworn ststement during the internal EBO investigation of the matter listed above. 

43. HAS ANY BUSINBSS OF WinCH YOU ARB OR WBREAN OFFICBR. DIRBCTOR, OR 

PARTNBRBEHN APARTYTO ANY ADMINISTRATIVE AGENCY PROCBBDING OR 

CRIMINAL OR CIVIL LITIGATION RBLEV ANT TO THE POSITION TO WinCH YOU HA VB 

BEEN NOMINATED? IF SO, PLEASE PROVIDE DETAILS. (WITHRBSPBCTTO A 

BUSlNBSS OF WinCH YOU ARB OR WERE AN OFFICBR, YOU NEED ONLY CONSIDER 

PROCBBDINGS AND LITIGATION THAT OCCURRED WHILE YOUWBRE AN OFFICER OF 

THAT BUSINBSS.) 

NIA 

44. HAVE YOUBVERBEHN THB SUBJECT OF ANY INSPBCI'OR GP.NBRAL 

INVESnGATION'l IF SO, PLEASE. PROVIDE DETAILS. 

I have been interviewed for l'nspector General investigations, but to my knowledge I have not been 

the subject ai an investigation. 

PARTF • SECJJ1UTY INFORMATION 

45. HA VB YOU BVERBEHNDBNJBD ANY SE.CURlTY a.E.ARANCE OR ACCESS TO 

CLASSIFIE.D INFORMATION FOR ANY REASON? IF YE.S, PLEASE EXPLAIN IN DETAIL. 

No 
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46. HA VB YOU BBBNREQUIRBD TO TAKE A POLYORAPHEXAMJNATION FOR ANY 

SECURITY CLBARANCB OR ACCESS TO CLASSJFIBD INFORMATION? IF YES, PLBASB 

EXPLAIN. 

Yes, I have taken several polygraphs during my time with the Intelll.geuce Community as part of 

routine security clearance background investigations and reinvestigations. 

47. HA VB YOUBVERRBFUSBD TO SUBMII' TO APOLYORAPHEXAMINATION? IF YES, 

PLBASBBXPLA;JN. 

No 

PARTG • APDmON6LINFQR.MA1lON 

48. DESCRIBE lN YOUR OWN WORDS THE CONCEPT OF CONGRESSIONAL OVERSIGHT OF 

U.S. INTBLLIGBNCB ACTlVlTIBS. lN PARTICULAR. CHARACTBRIZB WHAT YOU 

BBL1BVB TO BE THE OBUGATIONS OF THE INSPECTOR GENERAL OF THE NATIONAL 

RBCONNAISANCB OFFICBANDTHEINTBI.LlGBNCB COMMITTBBS OF THE CONGRESS 

RBSPEC11VBLY IN THE OVBRSIGHTPROCBSS. 

Congi:essional oversight plays a critical and unique role in regard to intelligence activities, which by 

their 1111t11re often must be undertaken in secret. Congr:easional oversight helps to ensure that intelljgem:c 

•vities are conductEd In compliance with the Constitution and law, accountable to the People, and in 

keeping with bur basic American values. While the heads of all intelligence elements have a statutory 

responsibility to keep the congressional intelligence committees fUlly and currently infonned of all 

intelligence activities, the responsibilities of Inspectors Oeueral are more specific: they must keep 

Congress fUlly and cummtly informed COiiceming fraud and other serions problems, abuses, and 

deficiencies relating to the administration of programs and the operations undertaken or :tinanced by 

agencies; to recommend corrective action concerning problems, abuses, and deficiencies; and to report on 

the progress made in implementing comclive actions. 

Inspectors General have a complementary oversight role, particularly within the InteJligence 

Community, where the Congress and the Inspectors General must be the eyes, ears, and conscience for . 

the American public wben transparency is not possible. The National Reconnaissance Offic;e performs 

vitsl missions for the Intelligence Community and the nation, and is e.nlrUsled with sJsnificant lllllOUD.Is of 

the taxpayer's fonds to carry ont those missions. The primary obligations of the National Reconnaissance 

Office Inspector 0euera1 and the congressi.ollal oveJ:8ight committees is to ensUie that these missions are 

met, that the taxpayers' funds are·shepherded and spent wisely, and that any abuses or deficiencies are brought to light and comcted. 

49. SXPLAINYOUR UNDERSTANDING OF THE RBSPONSlBn.mBS OF THE INSPECTOR 

GENERAL OF THBNATIONALRBCONNAISSANCB OFFICB. 

The duties of the National Peconnaissance Office Inspector General are spelled 011t in the Inspector 

Geneml Act of 1978. They Include the xesponsibility to condnct and supervise audits and investigationa 

of National Reconnaiuance Office's activities; to help the National ReconnaiiiSIInce Office leadership 

ensure that all activities are conducted economically, efficiently, and effectively, wisely using the 

resources made available by Congress; to prevent and detect iiand and abuse in National Reconnaissance 

Office programs and opemtions; to keep the Director of the National Reconnaissance Office and Congress 
48 

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fully and currently informed about problems and deficiencies relating 10 the National Recomlaissance 

Office's progi:ams and opeiadons; and 10 lllllke recommendations for corrective actions and ttaclc the 

implemlmtation of appropriate con:ective actions. · 

In addition, Jnspectors Geor:a1 in the Jnrelligence Community, 10 include the Inspector General for 

the National Rec:onnaialllllCC Office, play a vitD1 role by llllCC(Jiing and investigating reports from 

Jnrelligence Community whistleblowa:s wbilc also protecting national security information and 

inrelligence sources an!i methods, and also are responsible for helping 10 prolllCt whistleblowa:s from 

relaliation or reprisals. 

~~i~~~~-------

The fOI8QIIIilg 

TO THE CHAIRMAN, SBLBCr COMMlT'I'BE ONINTBUlGBNCB: 

In connection with my nomination 10 be the lnspector General of the National Recollllllissance 

respond 10 requests 10 appear and 1ll8tify before any duly 
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Pr•~tuu1r1nn Questions 

For 

Susan S. Gibson 

upon her nomination to be 

lnspec:tor General of the National Recormais&IU"'ce Office 

Page 1 of HI 
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Duties 

1. What is your understanding of the scope of the programs and activities within the 

responsibility and authority of the Director of the NRO? 

The scope of the National Reconnaissance Office's (NRO's) programs and activities is laid 

out in Executive Order 12333, which states that the NRO is ''responsible for research and 

development, acquisition, launch, deployment, and operation of overhead systems and 

related data processing facilities to collect intelligence and information to support national 

and departmental missions and other United States Government needs;" and for conducting 

foreign liaison in support of these missions within the framework laid out in other sections 

of the Executive Order. In addition to these core intelligence responsibilities, I would add 

the responsibility and authority of the Director to lead and manage the NRO, which 

includes the responsibility to judiciously and effectively manage and execute the 

taxpayer's funds entrusted to the NRO, and the responsibility to manage and provide for 

the professional development ofNRO personnel. 

2. Please «Jescribe your standards for an objective and effective office and how you 

intend to establish an office that maintains such standards? 

My standards for an objective and effective Inspector General (IG) office are very similar 

to my standards for an objective and effective General Counsel's Office. An objective and 

effective office requires individuals who take an open-minded, honest and thorough 

approach to acquiring the facts and understanding the circumstances; who know and 

support the missions of the NRO and the NRO Office oflnspector General (OIG); who 

identify and fairly apply the relevant laws, regulations and standards; and who act and 

think independently and with complete integrity. These are the same standards set forth by 

the Council of Inspectors General on Integrity and Efficiency (CIGIE). If confirmed, I will 

ensure that the NRO OIG staff continues to meet these standards and that they continue 

their professional development. I will be a role model for these standards myself, and 

remain vigilant in identifying and addressing any personal bias or any personal, 

organizational, or outside pressures or conflicts of interest, or other impediments to 

integrity or independence. 

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3. To what extent do you believe that the timeliness and responsiveness of reporting 

is an element of the effectiveness of an Inspector General? 

I believe that if an IG is not timely and responsive, she is generally not effective. IG 

findings and recommendations need to be provided promptly to be relevant and useful to 

the Director as she manages the NRO and to the Congress to assist in its oversight 

function. However, timeliness must be viewed in light of the need for thorough 

investigations, inspections, and audits. Findings and recommendations must be based 

upon solidly developed facts and presented in a clear, understandable manner. It is 

incumbent on the IG to establish appropriate internal controls and to ensure that the Office 

is striking the correct balance between speed and thoroughness in each case. 

4. What standards and procedures would you apply to ensure the appropriate 

timeliness and responsiveness of the NRO Office oflnspector General's (NRO 

OIG) completion of inspections, audits, reviews, and investigations? 

If confirmed, I would first examine the processes and internal controls at the NRO OIG, to 

determine the current standards and internal controls and assess their effectiveness. I 

would also compare the NRO OIG's current performance against the Quality Standards for 

Federal Offices of Inspector General, as published by CIGIE, and other relevant guidance 

and standards. I was pleased to learn that the NRO OIG issues flash reports regarding 

significant issues that need to be brought to management's attention prior to the 

completion of an audit, review, or investigation; this is a practice I would retain. The peer 

review process is also a valuable tool to assess the NRO OIG's standards and procedures. 

In April2014, the NRO OIG Audit Division passed a peer review conducted by the 

National Security Agency (NSA) OIG. A joint peer review led by NSA OIG of the NRO 

OIG Inspection Division began on 23 May 2016 and a peer review of the Audit Division is 

scheduled to begin in October 20 16. 

Protection of Whlstleblowers 

S. What formal policies and processes are in place to inform employees of their right 

to provide information to the NRO OIG and to detect and protect against reprisal 

for making complaints or disclosing information to the NRO OIG? 

All new employees are briefed by members of the OIG staff. The briefing includes 

information on their responsibility to notify the OIG of fraud, waste, and abuse; on how to 

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contact the OIG; and on the laws and NRO policy that protects whistleblowers against 

reprisal if they make a complaint or provide information to the OIG. There are several 

ways employees or contractors can contact the OIG. These include a confidential hotlink. 

proC!:SS on the NRO internal information system, both open and confidential contact 

information that is posted on NRO's unclassified website, and drop boxes in NRO 

facilities. In addition, NRO employees and contractors are encouraged to visit the OIG in 

their offices at Headquarters and in the field. 

6. If confirmed, what additional poUcies and processes wiD you estabUsh or 

recommend to the NRO Director to protect whistleblowers? 

If confirmed, I plan to review the current policies and processes to ensure that they fully 

and effectively protect whistleblowers and inform employees of their rights and 

protections. In particular, given the NRO's extensive relationships with contractors, I will 

ensure that all policies and processes include the whistleblower protections that apply to 

contractor personnel. 

Access to Information 

7. Please describe how you would resolve, including what remedies you would 

pursue, if an NRO employee or contractor refuses to provide access to records, 

reports, audits, reviews, documents, papers, recommendations or other materials 

requested by the NRO IG? 

If confirmed, I would seek to resolve any issues regarding access to records or other 

information through discussions with NRO's leadership and General Counsel, with a goal 

of resolving any issues at the lowest level. If an NRO employee is refusing to provide the 

requested materials, and discussions with the General Counsel and the Director fail to 

result in access by the OIG to those materials, I would notifY the oversight committees ifl 

felt the denial of such access was improperly interfering with the conduct of the work of 

the OIG. If a contractor refused to voluntarily provide access, I would notifY the NRO 

Office of Contracts that the contractor was failing to comply with its contractual 

requirements. If the contractor failed to comply voluntarily, I would issue a subpoena to 

the contractor. 

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8. What is your view of the appropriate use of subpoena authority? 

In my view, subpoena authority is a valuable and essential tool that should be used 

sparingly. 

Sources of Complaints 

9. If confirmed, what steps would you take to inform individuals, within or outside of 

the U.S. Government, including contractors, of their opportunity to provide such 

complaints or information to the Inspector General? 

If confirmed, I would assess the processes and mechanisms the NRO OIG currenily has in 

place to provide information about contacting the NRO OIG, and if needed, make 

appropriate improvements to the i>rocesses for informing individuals, within or outside the 

U.S. Government, of their abiUty to provide complaints, concerns, or information to the 

NRO IG, the Intelligence Community (IC) IG, or the Department of Defense (DoD) IG. 

Given the NRO's mission, information about how to contact the NRO IG, through both 

classified and unclassified means, should be readily available to both government and 

contractor personnel at NRO, and also available to the general public. 

Relationship to Other Inspectors General 

10. Please describe your priorities, if confirmed, for the work of the NRO OIG in 

relation to the work of other Inspectors General with responsibilities concerning 

intelligence programs and activities. 

During my nearly eleven years at the ODNI, I have learned and relearned the value of 

coordination and collaboration with interagency partners. If confirmed as the NRO IG, I 

would consult and coordinate regularly with the IC IG and the other IC member IGs, both 

individually and through the IC Inspectors General Forum, to ensure that OIG efforts 

across the IC are optimized. The NRO ha8 many mission partners, including the National 

Geospatial-Intelligence Agency (NGA) and the NSA. I would look for opportunities to 

continue the current NRO OIG practice of conducting joint reviews with these agencies 

when appropriate .. However, I expect that my priority would be to focus on matters of 

greatest importance to NRO's mission or other matters unique to the NRO. 

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11. Please also describe your goals, if confirmed, concerning the NRO OIG 

participation in the work of the Intelligence Community Inspectors General 

Forum and any measures you would recommend ·to .improve, if warranted, its 

functions. 

If confirmed, I intend to be an active member of the IC Inspectors General Forum. The 

Forum, both at the IG level and at the audit, inspection, investigation, and counsel 

committee levels, is critical to ensuring that the IC IGs are aware of each other's work. 

This awareness helps to reduce potential conflicts and to identify opportunities for joint 

work and collaboration. If confinned, and if during my participation in the IC IG Forum, I 

see opportunities for improvement, I will share my views with other members of the 

Forum and be an active participant in bringing about any needed improvements. 

Government AccountabUity OjJlce 

Pursuantto Section 348 of the Intelligence Authorization Act for Fiscal Year 2010, 

the Director of National Intelligence has issued a directive on the access of the 

Comptroller General to information in the possession of an element of the 

IntelUgence Community. 

12. ·Please describe your understanding of the role of the Government Accountability 

Office (GAO) in assisting Congress in oversight that relates to such information. · 

GAO's role in assisting Congress, as it relates to such infonnation, is to evaluate 

Intelligence Community programs and activities; and provide infonnation, analyses, 

options, recommendations, and other assistance to help the Congress make effective 

policy, funding, and oversight decisions. 

13. Please describe your views on what coordination between the NRO OIG and 

GAO would be desirable to assure full coverage of oversight requirements while 

avoiding conflict or duplication. 

My view is that frequent communication and coordination would assist both the NRO OIG 

and the GAO in accomplishing their respective oversight responsibilities. Coordination 

could also help deconflict and avoid a duplication of effort. This is particularly important 

during a constrained budget environment. 

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14. Intelligence Community Directive 114 governs the Comptroller General's access 

to Intelligence Community information. In recent deliberations on the GAO's role 

in scrutinizing NRO programs, the NRO offered that Congress should leverage the 

NRO OIG to perform specific inquiries that might otherwise be appropriate for 

the GAO. Historically, the NRO OIG has been quite amenable to these requests. 

Are you prepared to have your office support similar such requests? 

Yes, I would support similar requests. 

Independence 

15. If confirmed, in addition to this reporting responsibility, please describe what 

actions you would take if a senior NRO or IC official sought to prevent you from 

initiating, carrying out, or completing any audit or investigation within the 

jurisdiction of the NRO IG? 

The Inspector General Act authorizes only the Secretary of Defense, after consultation 

with the Director ofNational Intelligence, to prohibit the NRO OIG from initiating or 

completing any audit or investigation if necessary to protect vital national security 

interests. If this authority is used, the committees must be informed. Ifl believed that a 

senior NRO or IC official was improperly seeking to prevent the NRO OIG from carrying 

out its lawful functions, I would consult first with the individual's senior management, to 

include the NRO Director, and encourage them to consult with the NRO General Counsel. 

If not resolved, I would report the matter to the leadership of the congressional oversight 

committees. 

16. The NRO has dual reporting chains (DoD and IC); you are a political appointee; 

and you have statutory reporting obligations. How will you balance these 

competing equities and reporting obligations? 

Under the Inspector General Act, the responsibility of an inspector general is to keep the 

head of the establishment and the Congress fully and currently informed about problems 

and deficiencies relating to the administration of the agency's programs and operations. 

My status as a political appointee would have no bearing on these responsibilities. In my 

view, dual reporting chains would not necessarily create competing equities and reporting 

obligations. I have always found it best to err on the side of reporting ifthere is any 

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ambiguity or question about whether a report is required or whether additional oversight 

entities should receive the information. 

17. Please provide your views on how to build and maintain the integrity and 

independence of your OIG stall' to help them address organization pressures? 

Organizationally, the NRO IG and the OIG staff report to the Director of the NRO and do 

not report to any other NRO officer. This placement within the NRO helps the NRO OIG 

maintain its integrity and independence. To further protect the integrity and independence 

of its members, the OIG maintains an independent Career Service Board (CSB) for making 

informed decisions on assignments, awards, promotions, education/training, and 

administrative actions. Only senior members of the NRO OIG serve on the NRO OIG 

CSB, with the exception of one representative from Central Intelligence Agency (CIA) 

OIG when the CSB is reviewing NRO OIG personnel for possible promotion into the 

Senior Intelligence Service. Only the NRO IG can approve or disapprove 

recommendations from the NRO OIG CSB. 

OIG personnel also are required to complete the Office of Government Ethics Forms 450 

or 278. These forms are reviewed by their supervisors to safeguard against conflicts of 

interest that could affect the integrity of the OIG. In addition, at the beginning of each 

project, all OIG team members and project managers complete an Independence 

Certification. If any potential independence or integrity issues are noted, the issues must 

be mitigated or the individual will be assigned to another project. 

If confumed, I would continue these structures and processes and look for additional ways 

to improve the futegrity and independence of the OIG. I have always maintained an "open 

door'' policy and encourage employees under my supervision to seek guidance and 

assistance whenever they feel they are being subjected to inappropriate organizational 

pressures. I would continue this practice if confirmed as the NRO IG. 

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Inspector General Work Plan 

18. If confirmed, how will you determine the investigations and.reports that are 

necessary or desirable to eomplete each year? Would you anticipate developing a 

work plan for each year in office? 

I have had the opportunity to review the NRO OIG's current process for determining 

which investigations and reports are necessary or desirable and for developing its annual 

work plan. The process identifies oversight projects that address NRO mission risks; 

support the OIG's responsibilities to promote economy, efficiency, and effectiveness; and 

prevent and detect fraud, waste, and mismanagement. The current process includes 

identifying all congressionally required reviews, and engaging with stakeholders (to 

include congressional oversight committees) to identify mission risks and management 

challenges. If confirmed, I anticipate developing a work plan for each year I am in office. 

I also commit to undertaking unanticipated work based on congressional or NRO senior 

leadership concerns and emerging issues. 

Referrals to the Department of Justice 

19. Please describe your understanding of the authority and responsibiUty of the 

NRQ.QIG to. refer matters to the Department of Justice concerning possible 

criminal conduct, including the conduct of current or former officials? 

The basic Inspector General authorities and responsibilities for reporting possible criminal 

conduct, including allegations of criminal conduct by current or former officials, are found 

in section 4 of the Inspector General Act and in the 1995 Memorandum of Understanding: 

Reporting of Information concerning Federal Crimes, which addresses the reporting 

requirements in Executive Order 12333, and in 28 U.S.C. §535(b). If confirmed, I would 

be responsible for reporting to the Attorney General possible violations of the federal 1 

criminal laws by employees and others in a manner consistent with the protection of 

intelligence sources and methods. 

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20. In your view, what should be the role, if any, of other NRO omces or omcials, 

including the omce of General Counsel, in making referrals to the Department of 

Justice? · 

All Intelligence Community personnel have the responsibility to report potential criminal 

misconduct; employees may report criminal allegations to either the IG or the General 

Counsel. In accordance with Sections ill-V of the 1995 Memorandum of Understanding: 

Reporting of Information concerning Federal Crimes, the NRO Office of General Counsel 

is required to report possible violations offederal·and state criminal laws to the 

Department of Justice or to state or local Jaw enforcement authorities, subject to certain 

exceptions including, but not limited to, allegations subject to the OIG's jurisdiction that 

have been reported to the OIG. The NRO Office of General Counsel's military attorney 

also reviews possible violations of the Uniform Code of Military Justice to determine if 

referral through military command channels is appropriate. 

Consultations about Reports 

21. Under what circumstances, if any, do you believe it would be appropriate for the 

NRO OIG to consult with omcials in the NRO, or other omciais of an IC element 

outside an omce of an Inspector General, before issuing a report, regarding the 

fmdings and recommendations in the report? 

The NRO OIG's current practice of providing draft reports ofaudits, inspections, or 

special projects to NRO management to solicit comments and fact;ual corrections is 

appropriate and consistent with the standards set by CIGIE. Providing drafts of these 

reports to management for comment helps ensure that the reports are factually accurate, 

that findings and recommendations are supported by the facts, that classified information is 

properly identified, that proprietary and other similarly sensitive information is properly 

protected, and that the managers understand the underlying basis for the fmdings and 

recommendations. However, the fmal responsibility for determining appropriate findings 

and recommendations rests with the OIG. If a recommendation requires the NRO to 

coordinate with another agency, I would expect the IG of that agency to be informed of the 

matter. 

The NRO OIG also frequently teams with other OIGs in the IC to conduct joint reviews. 

The NRO OIG has found that 'Yorking with OIG members from across the IC on matters 

that affect other IC agencies creates a more accurate result with a broader perspective. It is 

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my understanding that for these joint reviews, the involved OIGs consult with the 

appropriate IC officials before issuing a final report to solicit comments and factual 

corrections. 

22. To the extent that you beHeve such consultation is appropriate, what steps, if any, 

do you beHeve the Inspector General should take to keep a record of the 

consultation and record the results in the text of the report? 

When the NRO OIG requests comments and technical accuracy reviews on draft reports, 

any comments or corrections should be submitted in writing. Any comments indicating 

disagreement with the NRO OIG's findings and recommendations should be made a part 

of the report, and other comments or corrections may be included as appropriate. All 

comments or discussions with management regarding a project or' case should be captured 

in the project or case working papers. 

23. Under what circumstances, if any, do you beHeve it would be appropriate for 

senior officials to request that the NRO OIG not investigate or review a particular 

matter? 

As noted in my response to Question 1 5, only the Secretary of Defense can prohibit the 

NRO IG from initiating any audit or investigation and only if such prohibition is necessary 

to protect vital national security interests. However, if a senior NRO official requested that 

a review be delayed because the review would likely interfere with critical on-going 

mission activities, I would discuss the situation with senior leaders in the NRO and in my 

office and determine whether delaying the review served the best interests of the NRO and 

the country. 

24. Under what circumstances, if any, do you believe it would be appropriate for 

senior officials to request that the NRO OIG not issue a report on a particular 

matter? 

As noted above, only the Secretary of Defense can prohibit the issuance of a report. If the 

investigation or review has been completed, there are circumstances where it would be 

appropriate to limit dissemination of a report, for example a report on a review of a highly 

compartmented program or an overhead collection operation in support of a covert action. 

Ho:w.e:v.er, the_report_would stilLat.a minimum be provided to the Director of-the.NRO and 

the chair and vice chair or ranking member of the oversight committees. 

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25. Under what circumstances, if any, do you believe it would be appropriate for 

senior officials to requeflt that the NRO OIG change fmdings, recommendations, 

or other pertinent material in a report on a particular matter? 

It is essential that reports issued by an IG are accurate. If confirmed, I intend to continue 

the NRO OIG's current practice of submitting draft reports to the affected directorates and 

offices for a review to ensure that the report is factually accurate and the recommendations 

are addressed to the appropriate officials. While I would welcome factual corrections and 

suggested changes to recommendations, I would not condone any requests to make 

changes to a report if the request were based on a desire to avoid embarrassment, to keep 

information from Congress, or for other inappropriate reasons. 

26. Please describe your views on the appropriate relationship between the NRO 

OIG and the NRO Office of Congressional Affairs when communicating with the 

Congress. 

The NRO OIG must maintain direct communication channels with Congress. At the same 

time, the NRO OIG generally should keep the NRO Office of Congressional and Public 

Affairs informed of communications with Congress. The final responsibility for 

determining appropriate coordination with the NRO Office of Congressional Affairs rests 

with the OIG. 

27. What is your position on the role of the NRO OIG to monitor NRO adherence to 

Congressional intent and direction? 

NRO's adherence to congressional intent and direction is foundational to its relationship 

with the Congress. Given the breadth ofNRO programs, the Congress implicitly trusts the 

NRO to comply with direction provided in its legislation and incorporated into classified 

annexes, or to communicate when any deviation is necessary and appropriate. The role of 

the NRO OIG in this process is to ensure that the NRO is honoring its commitment in this 

regard, and highlight any perceived deficiencies to NRO leadership andlto the 

congressional oversight committees as appropriate. 

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28. Please also describe your views on the appropriate relationship between the NRO 

OIG and the NRO Office of General Counsel when those communications involve 

legal issues. 

The Inspector General Act provides that an IG shall obtain legal advice from a counsel 

reporting either directly to the IGor to another IG. This construct provides the IG with 

independent legal advice on matters within the IG's purview, free from any real or 

perceived conflict that might occur. The role of the NRO General Counsel is to provide 

legal advice to the NRO's leadership concerning matters within the NRO's mission. 

However, legal advice from the IG's counsel will often benefit from consultation with the 

NRO's General Counsel. If confirmed, I would advise my counsel to work closely with 

the NRO's General Counsel on resolution of legal issues identified in the course of any 

investigations or review. This would enable the two offices to either reach an accord, or 

properly frame the issue when agreement on the resolution cannot be reached. I would 

expect my counsel to provide me with independent and objective advice that is informed 

by, but not inappropriately influenced, by those discussions. 

Major Challenges, Problems, and Priorities 

29. In your view, what are the major challenges facing the NRO OIG? 

I am not currently aware of any major challenges facing the NRO OIG. I assume that the 

NRO OIG, like every OIG, needs to ensure it has full and prompt access to the information 

needed to thoroughly investigate or review a matter, but I have not been informed of any 

particular problems with access to information. I also assume that there are budget and 

personnel resource constraints that limit the number of reviews the OIG can accomplish. 

The Acting IG has informed me that the office recently spent two days identifying and 

developing solutions to the issues of most importance to the staff and working on the 

strategic plan for the office. If confirmed, I will review those issues and the plan to get a 

better understanding of the challenges the staff feels it faces. 

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30. The NRO is emerging from a period wherein the ability of the organization to 

produce on schedule and budget major system acquisitions was questioned. Some 

problems persist, and the NRO remains under strict scrutiny. What is your 

perspective on the NRO IG's role in scrutinizing the performance of the NRO? 

In my view, the NRO IG's role should be to continue its oversight of major system 

acquisition to help the NRO make additional progress towards a more efficient, effective, 

and accountable acquisition process. Effective execution of major system acquisitions is 

one of the NRO's most important missions and it should receive commensurate NRO OIG 

oversight and scrutiny. 

Personnel and Budgetary Resources of the NRO DIG 

31. Please describe the present organization, staffing (both with respect to authorized 

positions and positions currently filled), training, and resources of the NRO OIG. 

The NRO OIG presently consists of the front office and five divisions. Those divisions are 

Audit, Inspections, Investigations, Management Services, and Special Projects. The NRO 

OIG staff consists of CIA officers, NRO Cadre personnel, and active duty Air Force 

members. The NRO OIG is currently about 90 percent staffed, with several additional 

personnel scheduled to arrive over the next 6 months. I have not had an opportunity to 

review the training records of the NRO OIG personnel but am told that they are meeting all 

of the training requirements established by CIGIE. The NRO OIG budget is classified. I 

have received an overview of the OIG budget and, if confirmed, will conduct an in-depth 

examination. 

32. If you are confirmed, what changes, if any, would you expect to consider or make 

in the present OIG with regard to organization, staff qualifications, training, 

budget, or other features relevant to the effective performance of the duties of the 

new statutory office? 

If confirmed, I will review the current organization, staff qualifications, training, and 

budget to ensure the NRO OIG can effectively perform its mission. The NRO OIG has 

been in existence since 1987 and was established as a designated federal entity IG in 2010. 

In my many years of military and government service, it has never been my practice to 

make major organizational changes as soon as T arrive. If confirmed, I will review the 

NRO OIG, consult with stakeholders inside and outside the office, to include the 

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congressional committees, and assess where improvements can be made. In my 

experience, training is one area that can almost always be improved, so I will start by 

looking for any training gaps or opportunities. 

33. To your knowledge, to what extent, if any, has the NRO OIG used contractors to 

perform audit and investigative functions? 

The Chief Financial Officers (CFO) Act of 1990, as amended by the Government 

Management Reform Act of 1994, and Office of Management and Budget Bulletin 14-02, 

requires an agency's IGor qualified independent public accountant under the direction of 

the IG, to audit an agency's financial statements. The NRO OIG uses the services of an 

independent public accounting firm to perform the audit of the NRO's annual financial 

statements. The NRO OIG also uses this firm to perform the Federal Information Security 

Modernization Act (FISMA) evaluation and the Statement on Standards for Attestation 

Engagements (SSAE) No. 16 examination. The NRO OIG oversees the work of the firm 

to ensure it is properly performed. The remaining oversight activities of the NRO OIG are 

conducted by NRO OIG government personnel. 

34. Under what circumstances, if any, do you believe that the use of contractors to 

perform such functions is appropriate? 

The NRO OIG's use of contractors to perform the audit of the NRO financial statements, 

the FISMA evaluation, and the SSAE 16 attestation is appropriate as permitted by the CFO 

Act and OMB Bulletin 14-02. While it may be necessary to obtain the services of a 

subject matter expert on a limited basis to support an audit or inspection, if confirmed, I 

have no plans to expand the use of contractors to perform additional audit or investigative 

functions. 

35. In your view, are there any barriers or disincentives, including any created by 

personnel policies, that impede the recruitment or retention of qualified IG 

personnel? If so, please describe. 

I am concerned that the current cadre staffmg allocations for the NRO OIG may limit its 

ability to recruit and retain personnel with the skills necessary to fully perform its mission. 

The NRO is undergoing a significant restructuring of its personnel system to incorporate a 

permanent cadre. If confirmed, I would review the NRO OIG's cadre, military, and 

detailee mix and seek changes as needed. 

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Oversight of Acquisition Programs and Contracts 

36. What role, if any, do you believe the NRO OIG should play in achieving 

acquisition reform? 

As part of the NRO OIO's continued commitment to providing value-added oversight of 

NRO acquisition practices, it must remain focused on NRO's acquisition reform progress 

and plans. For example, the NRO 010 must continue to evaluate the NRO's progress 

improving the professionalism of the acquisition workforce, which includes pf9gram 

management, engineering, contracting, and product support disciplines. In addition, the 

NRO 010 must continue to oversee efforts to improve competition, cost realism, and 

program risk reductions. 

37. What is your view of the role the NRO OIG should play in oversight, audit, and 

investigation over NRO contracts? 

In my view, the NRO OIG should continue to conduct independent and objective 

acquisition audits, inspections, and special reviews ofNRO contracts. These reviews 

should include the effectiveness of program management and acquisition planning at the 

NRO, which includes.a review of whether effective and responsible contracting practices 

were followed. I will also ensure that the investigations unit continues its strong 

investigative efforts focused on fraud and d.efective arid counterfeit parts, and make 

recommendations to correct any government practices that permitted fraud or contractor 

misconduct to occur. 

Questionnaire Follow-Up 

38. In your response to question 31ofthe Questionnaire yon completed on May 2, 

2016, you stated that you received interest in the amount of $45,212 in 2012. 

Could you please provide details about this amount, given that it far exceeds the 

amount of interest earned in the other calendar years reported? 

My husband and held dozens ofE and I Series U.S. Savings Bonds that we had 

accumulated through direct purchase and military payroll deductions early in our careers. 

In 2012, several of these bonds were approaching their full maturity dates. We decided to 

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redeem all of our remaining savings bonds that year, which resulted in an unusually large 

amount of interest income. 

39. In your response to question 38 of the Questionnaire you completed on May 2, 

2016, you indicated that you were the subject of a Professional Responsibility 

inquiry by the Army JAG Corps' Standards of Conduct Office. Could you please 

provide additional detaUs about this inquiry even though it was closed as 

unfounded? 

In the mid-1990s, I was the Deputy Staff Judge Advocate for Aberdeen Proving Ground. 

As such, I was the senior legal advisor to the U.S. Army Ordnance Center and School as 

the command addressed the legal, congressional, and public relations issues during the 

1996 investigations into allegations that drill sergeants and instructors sexually assaulted 

and raped trainees. Soon after the initial reports by trainees of rapes and other sexual 

assaults by drill sergeants and instructors at Aberdeen, I learned that some trainees were 

being read their Article 31 rights for ''false official statement" as soon as they began to 

make allegations against drill sergeants. 

Article 31 rights are required by Article 31 of the Uniform Code of Military Justice (10 

U.S.C. §831 ). They are similar to Miranda rights, but also include the requirement to 

inform the suspect of the "nature of the accusation." In practice, this means that suspects 

are "read their rights" for a particular offense or offenses. 

Ordnance School personnel were also subject to a local punitive regulation that made it a 

violation of a lawful order for trainees and drill sergeants/instructors to ''fraternize." As a 

result, if a trainee made statements to criminal investigators that could be perceived as 

admitting to fraternization (e.g., drinking with a drill sergeant, getting into a drill 

sergeant's car, travelling off the military installation with an instructor, etc.), they were 

being read their rights for violation of a lawful military order, in the form of this local 

punitive regulation. 

I was concerned that giving rights warnings in these circumstances could be perceived as 

attempting to intimidate the trainees from reporting allegations of misconduct. I took steps 

to stop improper rights warnings-such as the warnings given for false official statements 

as soon as the trainees began to report-and to appropriately limit other circumstances 

where trainees would be read their rights. 

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After the first wave of courts-martial concluded, the Office of the Army ;Inspector General 

thoroughly investigated the Aberdeen incidents and the command's response. During the 

investigation, there was an allegation that I had improperly instructed Army criminal 

investigators not to read Article 31 rights to trainees who admitted to violations of the 

punitive fraternization regulation. The Army OIG turned the matter over to the Army 

Judge Advocate General for resolution, and the JAG Corps Standards of Conduct Office in 

turn assigned an investigator to examine the facts surrounding this allegation. The 

investigator concluded that the allegation against me was unfounded. The Standards of 

Conduct Office concurred with the fmdings and closed the case as unfounded. 

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UNITED STATES OFFICE OF SSCI# 

GOVERNMENT ETHICS 

The Honorable Richard Burr 

Chairman 

Select Committee on Intelligence 

United States Senate 

Washington, DC 20510 

Dear Mr. Chairman: 

* 

APR 2 5 2016 

2016-165 8 

In accordance with the Ethics in Government Act of 1978, I enclose a copy of the 

financial disclosure report filed by Susan S. Gibson, who has been nominated by President 

Obama for the position of Inspector General, National Reconnaissance Office. 

We have reviewed the report and have obtained advice from the agency concerning any 

possible conflict in light of its functions and the nominee's proposed duties. Also enclosed is an 

ethics agreement outlining the actions that the nominee will undertake to avoid conflicts of 

interest. Unless a date for compliance is indicated in the ethics agreement, the nominee must 

fully comply within three months of confirmation with any action specified in the ethics 

agreement. 

Based thereon, we believe that this nominee is in compliance with applicable laws and 

regulations governing conflicts of interest. 

Enclosures 

Sincerely, 

General Counsel 

1201 New York Avenue, NW, Suite 500 I Washington, DC 20005 

www.oge.gov 
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Mr. Robert S. Taylor 

Acting Gencm1 COunsel and 

Acting Designated Agency Ethics Official 

Office of the General Counsel 

Department ofDeCc:niJe 

Washington DC 20310 

Dear Mr. Taylor: 

APR I' 8 2016 

The purpose of this letter is to describe the steps that I will take to avoid any actual or 

apparent conflict of interest in the event that I am confirmed for the position of Inspector General 

for the National Reconnaissance Office. 

As required by 18 U.S.C. § 208(a), I will not participate personally and subsmntially in 

any particular matter in which I know that I have a financial interest directly and predictably 

affected by the matter, or in which I know that a person whose interests an: imputed to me has a 

fimmcial interest directly and predictably affected by the matter, unless I first obtain a written 

waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a tegtdatory exemption, pursuant to 

18 U.S.C. § 208(b)(2). I understand that the interests of the following persons an: imputed to me: any spouse or minor child of mine; any general partner of a partnership in which I am a limited 

or general partner; any organization in which I serve as officer, director, 1rustee, general partner 

or employee; and any person or organization with which I am negotiating or have an 

II1'1'IIJlgell1 concerning prospective employment. 

Upon my confirmation, I will resign from my position as CJenepd Counsel to the Boanl of 

Women in Technology and from my Board member position with the City of Fairfax Theatre 

Company. For a period of two years from the date of my appointment, I will not participate 

personally and substantially in any particular matter involving specific parties in which either of 

these entities is a party or represents a party, unless I am first authorized to participate. pursualit 

to S C.P.R.§ 263S.S02(d) and Section 3 ofExecutive Order 13490. 

My spouse is the sole owner ofParasang Solutions. L.L.C •• For as long as my spouse owns Parasang Solutions L.L.C., I will not participate personally and substantially in any 

particular matter that to my knowledge bas a direct and predictable effect on the fimmcial 

interests ofParasang Solutions L.L.C., unless I first obtain a written waiver, pursuant to 

18 U.S.C. § 208(b)(l). I also will not participate personally and subsl8ntially in any particular 

matter mvolving specific parties in which I know a client ofParasang Solutions, L.L.c;is a party or represents a party, unless I am first authorized to participate, pursuant to S C.P.R. § 

263S.S02(d). 

My spouse is an operational advisor for lnnerProduct Partners, L.P. (IPP-L.P.), a venture 

capital partnership. By virtue of this position, he is entitled to carried interest that results from 

the profits ofiPP-L.P., which is held by lnnerProdUct Partners GP, L.L.C. (IPP-GP). I will not 

participate personally-and substantially in-any-particular matter·thatto my-knowledge-has a-direct 

and predictable effect on my spouse's employment with, or compensation from, IPP..OP ,liDleSs I 
69 

LAP51NQ082 with DISTILLER


Insert offset folio 48 here 22967.048

first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l). I also will not participate 

personally and substantially in any particular matter involving specific parties in wblch I know 

IPP.QP is a party or represents a party, unless 1 am first authorized to participate, pursuant to 

S C.F.R. § 263S.502(d). In addition, as a result of my spouse's carried intmest, I~ not 

participate personally and substantially in any particular matter tbat to my knowledge bas a direct 

and predictable effect ICC-L.P., unless I first obtain a written waiver, pursuant to 18 U.S.C. 

§ 208(b)(l). 

My spouse is also a limited partner investor in IPP-L.P., which makes venture capital 

investments, principally by investing in and holding equity and equity-oriented securities of 

privately held companies in early-stage technology businesses. My spouse is contractually 

locked into this Limited Panner:ship Agreement. The fund agreCm.ent requires my spouse to 

make capital commitments on demand. By virtue of his position as operational advisor for IPPL.P. my spouse provides input regarding investments, however, he docs not make final decisions 

regarding the actual investments. Two current holdings of IPP-L.P., Bridan Communications 

and MicroPBT, are on the DoD contractor list and will be included in my screening arrangement. 

As IPP-L.P. notifies my spouse of additional investments, I will promptly notify my ethics 

official to determine if any company is on the DoD contractor list or poses a conflict of interest 

with my duties as an Inspector General. Any such entity will be added to my screening 

arrangement for as long as the limited partnership holds the entity. ACCOidingly, for as long as 

my spouse owns these interests, I will not participate pelSODally and substantially in any 

particular matter tbat to my knowledge bas a direct and predictable effect on the financial 

interests of either Bridan Communications or MicroPET, unless I first obtain a written waiver, 

pursuant to 18 U.s:c. § 208(b)(l), or qualify for a regulatorY exemption, pursuant to 18 U.S.C. § 

208(b)(2). In addition, with regard to IPP-L.P., I will not participate personally and substantially 

in any particular matter tbat to my knowledge bas a direct and predictable effect on the financial 

interests of IPP- L.P. or its underlying assets, 'unless I first obtain a written waiver, pursuant to 18 

U.S.C. § 208(b)(l), or qualify far a regulatory CXCJl;lption, pursuant to18 U.S.C. § 208(b)(2);· 

I understand that as an appointee I am required to sign the Ethics Pledge (Exec. Order 

No. 13490) and tbat I will be bonnd by the requirements and restrictions therein in addition to the 

commitments I have made in this ethics agreement. 

I have been advised tbat this ethics agreement will be posted publicly, coDSistent with 

5 U.S.C. § 552, on the website of the U.S. Office of Government Ethics with ethics agreements 

of other Presidential nominees who file public financial disclosure reports. 

2 

Insert offset folio 49 here 22967.049LAP51NQ082 with DISTILLER

OOB Fonn 278e (Min:h 2014) :t?§;;!!!b!cs; S C.P.R. N::Z I Fonn Approyed; OMB No. (3209-0001) 

I=~ -in.&.c I I 

Executive Branch Personnel Public Financial Disclosure Report (OGE Fonn 278e) 

- APa i a c~~s '1/25//~ 

UNIT&D STATES OF

GOVERNMENT E

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Insert offset folio 50 here 22967.050LAP51NQ082 with DISTILLER

(lOE Piwm (Manllll01<4) 

lnstru.ttlons for Partl 

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FDer's!'1111110 PageNUinb+r 

Gibson, Susan S. 2·of10 

Part 1: FDer's' PositionsJield Onlside United States Go.vemment 

is N,uie City/State .· Orlianizatloa Type · PositiOn Held From 

1. Women In Technology , Falls cnurcn. VA No!>ilmfit Prole-Organlz8tiDn. GeriOI'al COunsel to me BCIIIRI 0812016 

2. Gity of FaiJfax Theatr&·eomp_any Fakfax, VA Non"Pttitlt Community Theel"' Boord Member 

3. l.lvln!l•Trust fQr Self Fallf!I!<,VA T!ll8t It! !flee 08/201'\ 

4. Revooabls Uldng Trust for Spouse. Fallf!I!<,VA Trust . Co-ilustee 0812014 

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Instructions for Part2 

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Gibson, Susan S. I 4of1

Part 3: l'iler'1 Emplo)'m< ~at tuad .. 

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llet'sName C: IJ'age Number Glbson.-susan·s~ " I 5,of10 Pa,rl 4; Filerls;Sourees of CompCIIlll!tioJi·ExeeediJill $5,000 in a Ye_ar ~-·· soun;e:~nt-• City/State Brief Description or Dulles 

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