Page 1 GAO-18-505R Nuclear Nonproliferation

441 G St. N.W.

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June 18, 2018

Congressional Committees

Nuclear Nonproliferation: The Administration’s 2015 Plan and 2017 Update for Nuclear 

Proliferation Verification and Monitoring Generally Did Not Address Reporting 

Requirements

In the National Defense Authorization Act (NDAA) for Fiscal Year 2015,1 Congress included a 

provision directing the President to develop and submit to certain congressional committees an 

interagency plan for verification and monitoring of the potential proliferation of nuclear weapons, 

components of such weapons, and fissile material.2 This provision came out of congressional 

concerns that were highlighted in a 2014 report on nonproliferation monitoring and verification 

technologies from the Department of Defense’s Defense Science Board.3 The NDAA provision 

specified four reporting requirements:

(1) An interagency plan and road map for verification and monitoring, with respect to 

policy, operations, and research, development, testing, and evaluation, including

• identifying requirements (including funding requirements) for such verification 

and monitoring; and

• identifying and integrating roles, responsibilities, and planning for such 

verification and monitoring.

(2) An engagement plan for building cooperation and transparency to improve 

inspections and monitoring.

(3) A research and development (R&D) program to 

• improve monitoring, detection, and in-field inspection and analysis 

capabilities, including persistent surveillance, remote monitoring, and rapid 

analysis of large data sets, including open-source data; and 

• coordinate technical and operational requirements early in the process.

 1

Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act for Fiscal Year 2015, Pub. L. No. 113-

291, §3133, 128 Stat. 3292, 3896 (2014). 

2

Weapons-usable nuclear materials are often referred to as fissile materials or strategic special nuclear materials. 

Such materials are highly enriched uranium, uranium-233, and plutonium containing less than 7 percent of the 

isotope plutonium-240.

3

Department of Defense, Defense Science Board, Task Force Report: Assessment of Nuclear Monitoring and 

Verification Technologies (Washington, D.C.: January 2014). 
Page 2 GAO-18-505R Nuclear Nonproliferation

(4) Engagement of relevant departments and agencies of the federal government and 

the military departments (including the Open Source Center and the United States 

Atomic Energy Detection System), national laboratories, industry, and academia. 

The administration submitted this classified plan to the congressional committees in October 

2015.

The fiscal year 2017 NDAA directed the President to provide certain congressional committees 

with a “comprehensive and detailed” update to the October 2015 plan.4 The legislation did not 

specify any new reporting requirements. This classified update was submitted to the 

congressional committees in May 2017. The fiscal year 2018 NDAA requires the Department of 

Energy to produce a new plan.5 The National Nuclear Security Administration (NNSA),6 in 

consultation with interagency partners, submitted this plan to the congressional committees in 

April 2018.7

The conference report accompanying the fiscal year 2018 NDAA includes a provision for GAO 

to review and submit an assessment of the October 2015 plan and the May 2017 update.8 This 

report assesses the extent to which the 2015 plan and the 2017 update addressed the reporting 

requirements. This is a public version of a classified report that we issued in March 2018.9 This 

report omits certain details regarding administration plans and priorities for nuclear proliferation 

verification and monitoring that NNSA deemed to be classified. Although the information 

provided in this report is less detailed, it addresses the same objective as our classified report. 

In addition, the overall methodology used for both reports is the same.

To address this objective, we reviewed the 2015 plan and the 2017 update. We assessed the 

content of the 2015 plan and the 2017 update against the reporting requirements and we rated 

the extent to which each document addressed those requirements in one of three ways: (1) 

addressed the reporting element with detail; (2) addressed the reporting element but without 

detail; or (3) did not address the required reporting element. In assessing the level of detail, we 

considered key factors identified in our previous work on national strategies, federal planning, 

and interagency collaboration. For example, we considered the extent to which the plan or the 

update provided information regarding specific goals or objectives; strategies to achieve those 

goals or objectives and how these strategies would be implemented; which agency or agencies 

would implement the strategies; and other measurable data, such as timelines and the 

 4

National Defense Authorization Act for Fiscal Year 2017, Pub. L. No. 114-328, §3132, 130 Stat. 2000, 2768 (2016).

5

National Defense Authorization Act for Fiscal Year 2018, Pub. L. No. 115-91, §3136 (2017).

6

NNSA, a separately organized agency within the Department of Energy, is responsible for the management and 

security of the nation’s nuclear weapons and nonproliferation programs. 

7

We have ongoing work to assess NNSA’s April 2018 plan. 

8

H.R. Rep. No. 115-404, at 1096 (2017) (Conf. Rep.).

9

GAO, Nuclear Nonproliferation: The Administration’s 2015 Plan and 2017 Update for Nuclear Proliferation 

Verification and Monitoring Generally Did Not Address Reporting Requirements, GAO-18-372RC (Washington, D.C.: 

Mar. 30, 2018).
Page 3 GAO-18-505R Nuclear Nonproliferation

resources required.10 We also interviewed officials at the Department of State (State) and NNSA 

who were involved in the development of the 2015 plan and the 2017 update or who reviewed 

those documents.

We conducted this performance audit from December 2017 to March 2018 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objective. We 

subsequently worked with NNSA and State from April 2018 through June 2018 to prepare this 

unclassified version of the original classified report for public release. This public version was 

also prepared in accordance with these standards.

The Administration’s Nuclear Proliferation Verification and Monitoring Plan and Update 

Generally Did Not Address Reporting Requirements 

The 2015 nuclear proliferation verification and monitoring plan and the 2017 update to the plan 

generally did not address the four reporting requirements. Both the 2015 plan and the 2017 

update were short—two and four pages long, respectively—and did not include key details of 

the types we have identified in previous work on national strategies and interagency 

collaboration, such as details on specific objectives, strategies to achieve those objectives, roles 

played by specific agencies, and resources required. 

The October 2015 plan was mostly a description of an organizational structure and interagency 

process intended to address nuclear proliferation, monitoring, and verification. Specifically, the 

plan focused at a high level on describing the role and composition of an Executive Committee 

and two subcommittees—an R&D Subcommittee and a Synchronization Subcommittee—that 

would constitute an interagency process to address four issue areas related to nuclear 

proliferation verification and monitoring.11 The plan did not include any specific details that could 

serve as a road map.

The 2017 update included the same description of the committee structure and interagency 

process that was presented in the 2015 plan. The 2017 update indicated that the Executive 

Committee had established a statement of priorities on nuclear proliferation, and the R&D and 

Synchronization Subcommittees had developed findings and produced strategies to address the 

statement of priorities. The 2017 update also indicated that the process led to the development 

of specific strategies, recommendations, and actions. 

 10These criteria are outlined in GAO’s previous work on characteristics of national strategies, federal planning, and 

enhancing collaboration in interagency groups. See GAO, Combating Terrorism: Evaluation of Selected 

Characteristics in National Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004); Results 

Oriented Government: Practices That Can Help Enhance and Sustain Collaboration Among Federal Agencies, GAO06-15 (Washington, D.C.: Oct. 21, 2005); Environmental Justice: EPA Needs to Take Additional Actions to Help 

Ensure Effective Implementation, GAO-12-77 (Washington, D.C.: Oct. 6, 2011); and Managing for Results: 

Implementation Approaches Used to Enhance Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: 

Feb. 14, 2014).

11These four issue areas are: (1) developing clear priorities and policy guidance, (2) avoiding duplication and 

otherwise optimizing U.S. capabilities through improved coordination and communication, (3) aligning research and 

development to intelligence-informed priorities, and (4) developing opportunities to enhance detection through 

authorities and activities across government.
Page 4 GAO-18-505R Nuclear Nonproliferation

In our assessment of the content of the 2015 plan and the 2017 update, we found that the plan 

and the update either did not address or did not address with detail any of the reporting 

requirements. Specifically, we found the following: 

• Regarding the reporting requirement on an interagency plan and roadmap for verification 

and monitoring, we found that neither the 2015 plan nor the 2017 update addressed this 

requirement. As noted above, the plan did identify four areas and stated that the 

Administration had developed an interagency process to address nuclear proliferation, 

verification, and monitoring. However, discussing a process does not constitute a plan or 

a roadmap for verification and monitoring. For instance, the document does not contain 

any planning details, such as the types of strategies that would be pursued or how the 

goals would be achieved, interagency roles or responsibilities, timelines, and resource 

requirements. The 2017 update, as noted above, mentioned strategies established by 

the subcommittees described in the 2015 plan. However, the 2017 update did not 

provide detail on these strategies. It mentioned some recommendations and actions, 

including adjusting U.S. policy to allow intelligence exchanges with partner countries, but 

it was unclear how these specific actions were related to an overall strategy or plan. 

Additionally, the Executive Committee established a statement of priorities for five areas 

of nuclear proliferation concern. We omit specific details of these priorities in this report 

because the information is classified. The R&D and Synchronization Subcommittees 

developed strategies to address those priorities. None of these strategies were outlined 

in the update. 

• Regarding the reporting requirement on an engagement plan for building cooperation 

and transparency to improve inspections and monitoring, we found that the 2015 plan 

and 2017 update did not address this requirement. Neither the 2015 plan nor the 2017 

update included a specific engagement plan for improving inspections and monitoring. 

The 2017 update specified two actions to engage partner countries, such as Israel and 

Japan, through intelligence exchanges on regional neighbors and key issues, as well as 

actions to increase information sharing between federal departments and the intelligence 

community. However, these actions are not discussed as part of a larger engagement 

plan and do not address inspections and monitoring.

• Regarding the reporting requirement on preparing an R&D program to improve 

monitoring, detection, and inspection and analysis capabilities and to coordinate 

technical and operational requirements, we found that the 2015 plan and the 2017 

update did not address this requirement. The 2015 plan did not mention an R&D 

program that focused on the areas listed in the reporting requirement. The 2017 update 

mentioned that the R&D Subcommittee formed several working groups that focused on 

issues including nuclear test detection; special nuclear material production detection; 

tagging, tracking, and locating; and data science. However, the update did not include 

an R&D program addressing the required areas. 

• Regarding the reporting requirement on engagement of relevant departments and 

agencies, we found that the 2015 plan and the 2017 update addressed this reporting 

requirement but without providing details. Both the 2015 plan and the 2017 update listed 

many departments and agencies involved in nuclear monitoring and verification work 

that are part of the Executive Committee, the R&D Subcommittee, or the 

Synchronization Subcommittee. However, the documents did not fully explain how the 

departments and agencies will be engaged, what their roles and responsibilities in the 

process are, or what resources they will contribute.
Page 5 GAO-18-505R Nuclear Nonproliferation

Table 1 summarizes the results of our analysis comparing the 2015 plan and the 2017 update 

against each of the reporting requirements. 

Table 1: Extent to Which the 2015 Nuclear Monitoring and Verification Plan and 2017 Update 

Addressed Reporting Requirements

Reporting requirements

GAO assessment 

of how the 2015 

plan addressed 

the element

GAO assessment 

of how the 2017 

update addressed 

the element

An interagency plan and roadmap for verification 

and monitoring with respect to policy, operations, 

and research, development, testing, and evaluation, 

including (1) identifying requirements (including 

funding requirements) for such verification and 

monitoring; and (2) identifying and integrating roles, 

responsibilities, and planning for such verification 

and monitoring.

Did not address Did not address

An engagement plan for building cooperation and 

transparency to improve inspections and monitoring. 

Did not address Did not address

A research and development program to (1) improve 

monitoring, detection, and in-field inspection and 

analysis capabilities, including persistent 

surveillance, remote monitoring, and rapid analysis 

of large data sets, including open-source data; and 

(2) coordinate technical and operational 

requirements early in the process.

Did not address Did not address

Engagement of relevant departments and agencies 

of the federal government and the military 

departments (including the Open Source Center and 

the United States Atomic Energy Detection System), 

national laboratories, industry, and academia.

Addressed, but 

without detail

Addressed, but 

without detail

Source: GAO analysis of 2015 nuclear verification and monitoring plan and 2017 update. | GAO-18-505R

Officials at State and NNSA told us that National Security Council (NSC) staff directed State to 

take the lead in clearing and submitting the 2015 plan and the 2017 update. According to State 

officials, NSC provided guidance on the scope and content of the 2015 plan and the 2017 

update. For the 2015 plan, NSC provided a two-page draft which State cleared with the 

interagency. For the 2017 update, State drafted the document, sent it to NSC for comments, 

and then sent the document to the interagency for clearance. State and NNSA officials we 

interviewed gave two reasons why the 2015 plan and the 2017 update generally did not address 

the reporting requirements and were not comprehensive. First, State officials told us that the 

2015 plan was a description of the organization of and process for interagency implementation 

of an August 2015 presidential policy directive (PPD). According to State officials, the PPD was 
Page 6 GAO-18-505R Nuclear Nonproliferation

NSC’s response to the 2014 Defense Science Board report and was intended to ensure 

interagency cooperation in identifying and addressing gaps in the U.S. nuclear proliferation 

detection and early warning programs. NNSA officials believed the PPD was inspired in part by, 

but was not a direct response to, the Defense Science Board report. Second, State and NNSA 

officials said that, at the direction of NSC staff, the 2015 plan and the 2017 update were kept 

brief rather than providing a detailed response to the reporting requirements. An NNSA official 

involved in the preparation of the new plan for 2018 said that it would provide a more 

comprehensive level of detail than the 2015 plan and 2017 update.

Agency Comments

We provided a draft of the classified version of this report to State and NNSA for review and 

comment. State had no comments on the draft report. NNSA commented that it does not agree 

with the statement that the PPD was established as a direct response to the 2014 Defense 

Science Board report. Instead, NNSA stated that the NSC was already working on plans for 

interagency coordination when the Defense Science Board report was released, but the 

Defense Science Board report helped broaden the NSC’s plans. NNSA stated that it believes 

the PPD is responsive to a subset of Defense Science Board recommendations. We clarified 

NNSA’s views in our classified report. We also provided a draft of this unclassified version of the 

report to NNSA for comment, but State indicated it did not wish to review or comment on the 

unclassified version. NNSA did not have any comments on the unclassified version of the 

report.

________

We are providing copies of this product to the appropriate congressional committees, the 

Secretary of State, and the NNSA Administrator. In addition, the report is available at no charge 

on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-3841 or 

trimbled@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs 

may be found on the last page of this report. GAO staff who made major contributions to this 

report include William Hoehn (Assistant Director), Antoinette Capaccio, and Alisa Carrigan.

David C. Trimble

Director, Natural Resources and Environment
Page 7 GAO-18-505R Nuclear Nonproliferation

List of Committees

The Honorable John McCain

Chairman 

The Honorable Jack Reed

Ranking Member 

Committee on Armed Services 

United States Senate 

The Honorable John Thune

Chairman 

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation 

United States Senate 

The Honorable Lisa Murkowski

Chairman

The Honorable Maria Cantwell

Ranking Member 

Committee on Energy and Natural Resources 

United States Senate

The Honorable Bob Corker

Chairman 

The Honorable Robert Menendez 

Ranking Member 

Committee on Foreign Relations 

United States Senate 

The Honorable Ron Johnson

Chairman 

The Honorable Claire McCaskill 

Ranking Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Richard Burr

Chairman 

The Honorable Mark Warner

Vice Chairman 

Select Committee on Intelligence

United States Senate 
Page 8 GAO-18-505R Nuclear Nonproliferation

The Honorable Richard Shelby

Chairman

The Honorable Dick Durbin

Ranking Member 

Subcommittee on Defense 

Committee on Appropriations 

United States Senate 

The Honorable Lamar Alexander

Chairman

The Honorable Dianne Feinstein 

Ranking Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

United States Senate 

The Honorable Lindsey Graham 

Chairman

The Honorable Patrick Leahy

Ranking Member 

Subcommittee on State, Foreign Operations, and Related Programs 

Committee on Appropriations 

United States Senate 

The Honorable Mac Thornberry 

Chairman 

The Honorable Adam Smith

Ranking Member 

Committee on Armed Services

House of Representatives

The Honorable Greg Walden 

Chairman 

The Honorable Frank Pallone

Ranking Member 

Committee on Energy and Commerce 

House of Representatives

The Honorable Ed Royce

Chairman 

The Honorable Eliot Engel

Ranking Member 

Committee on Foreign Affairs

House of Representatives

The Honorable Michael McCaul 

Chairman 

The Honorable Bennie Thompson

Ranking Member 

Committee on Homeland Security

House of Representatives
Page 9 GAO-18-505R Nuclear Nonproliferation

The Honorable Trey Gowdy

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Devin Nunes 

Chairman 

The Honorable Adam Schiff

Ranking Member 

Permanent Select Committee on Intelligence 

House of Representatives

The Honorable Kay Granger 

Chairwoman

The Honorable Pete Visclosky

Ranking Member 

Subcommittee on Defense

Committee on Appropriations 

House of Representatives

The Honorable Mike Simpson

Chairman 

The Honorable Marcy Kaptur

Ranking Member

Subcommittee on Energy and Water Development, and Related Agencies 

Committee on Appropriations

House of Representatives 

The Honorable Hal Rogers

Chairman

The Honorable Nita Lowey

Ranking Member 

Subcommittee on State, Foreign Operations, and Related Programs 

Committee on Appropriations 

House of Representatives

(102722)
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