Information Security: FAA Needs to Address Weaknesses in Air Traffic Control Systems
Published: 2015-01-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In support of its mission, FAA relies on the NAS—one of the nation's critical infrastructures—which is comprised of air traffic control systems, procedures, facilities, aircraft, and people who operate and maintain them. Given the critical role of the NAS and the increasing connectivity of FAA's systems, it is essential that the agency implement effective information security controls to protect its air traffic control systems from internal and external threats.
GAO was asked to review FAA's information security program. Specifically, the objective of this review was to evaluate the extent to which FAA had effectively implemented information security controls to protect its air traffic control systems. To do this, GAO reviewed FAA policies, procedures, and practices and compared them to the relevant federal law and guidance; assessed the implementation of security controls over FAA systems; and interviewed officials. This is a public version of a report containing sensitive security information. Information deemed sensitive has been redacted.
section_title: What GAO Found
paragraphs: While the Federal Aviation Administration (FAA) has taken steps to protect its air traffic control systems from cyber-based and other threats, significant security control weaknesses remain, threatening the agency's ability to ensure the safe and uninterrupted operation of the national airspace system (NAS). These include weaknesses in controls intended to prevent, limit, and detect unauthorized access to computer resources, such as controls for protecting system boundaries, identifying and authenticating users, authorizing users to access systems, encrypting sensitive data, and auditing and monitoring activity on FAA's systems. Additionally, shortcomings in boundary protection controls between less-secure systems and the operational NAS environment increase the risk from these weaknesses.
FAA also did not fully implement its agency-wide information security program. As required by the Federal Information Security Management Act of 2002, federal agencies should implement a security program that provides a framework for implementing controls at the agency. However, FAA's implementation of its security program was incomplete. For example, it did not always sufficiently test security controls to determine that they were operating as intended; resolve identified security weaknesses in a timely fashion; or complete or adequately test plans for restoring system operations in the event of a disruption or disaster. Additionally, the group responsible for incident detection and response for NAS systems did not have sufficient access to security logs or network sensors on the operational network, limiting FAA's ability to detect and respond to security incidents affecting its mission-critical systems.
The weaknesses in FAA's security controls and implementation of its security program existed, in part, because FAA had not fully established an integrated, organization-wide approach to managing information security risk that is aligned with its mission. National Institute of Standards and Technology guidance calls for agencies to establish and implement a security governance structure, an executive-level risk management function, and a risk management strategy in order to manage risk to their systems and information. FAA has established a Cyber Security Steering Committee to provide an agency-wide risk management function. However, it has not fully established the governance structure and practices to ensure that its information security decisions are aligned with its mission. For example, it has not (1) clearly established roles and responsibilities for information security for the NAS or (2) updated its information security strategic plan to reflect significant changes in the NAS environment, such as increased reliance on computer networks.
Until FAA effectively implements security controls, establishes stronger agency-wide information security risk management processes, fully implements its NAS information security program, and ensures that remedial actions are addressed in a timely manner, the weaknesses GAO identified are likely to continue, placing the safe and uninterrupted operation of the nation's air traffic control system at increased and unnecessary risk.
section_title: What GAO Recommends
paragraphs: GAO is making 17 recommendations to FAA to fully implement its information security program and establish an integrated approach to managing information security risk. In a separate report with limited distribution, GAO is recommending that FAA take 168 specific actions to address weaknesses in security controls. In commenting on a draft of this report, FAA concurred with GAO's recommendations.

section_title: Letter
paragraphs: The Federal Aviation Administration (FAA) performs critical functions that  contribute to ensuring safe, orderly, and efficient air travel in the national  airspace system (NAS). Effective air traffic control (ATC) relies on  automated systems and networks to provide information to air traffic  controllers and aircraft flight crews to work toward ensuring safe and  expeditious movement of aircraft. As a piece of critical infrastructure  within the nation’s transportation sector, the NAS is vitally important in  supporting air traffic control operations nationwide, and disruptions could  have a significant adverse impact.
Cyber-based threats to federal information systems such as those that  FAA relies on for its ATC systems are evolving and growing. These  threats can be intentional or unintentional and can come from a variety of  sources, including criminals, foreign nations, terrorists, and other  adversarial groups. For example, advanced persistent threats—where an  adversary that possesses sophisticated levels of expertise and significant  resources can attack by using multiple means such as cyber, physical, or  deception to achieve its objectives—pose increasing risks. Further, the growing interconnectivity among different types of information systems  presents increasing opportunities for such attacks. Because of the  increasing number of reported information security incidents, coupled with  the advancement of security attacks, information and systems at FAA and  across the government remain at risk.
Given the critical role the NAS plays in the nation’s transportation sector  and the growing threats to federal information systems, you asked us to  review FAA’s information security program. The specific objective of our  review was to evaluate the extent to which FAA has effectively  implemented appropriate information security controls to protect the  confidentiality, integrity, and availability of its existing ATC systems.
This is a public version of a limited distribution report containing sensitive  security information that we provided to you. Some of the information in  the prior report has been designated as sensitive security information and  must be protected from public disclosure. Therefore, this report does not  contain detailed descriptions of the control weaknesses and related  recommendations identified during our review. Although the information  provided in this report is less detailed, it presents the same overall  message as the limited distribution report. Also, the overall methodology  used for both reports is the same.
To assess FAA’s implementation of security controls on its existing ATC  systems, we compared FAA’s documented policies, procedures, and  practices with the relevant information security law and federal guidance,  including National Institute of Standards and Technology (NIST)  standards and guidelines. We also assessed the implementation of  controls over NAS supporting systems and interconnections by examining  risk assessment processes, security plans, security control assessments,  contingency plans, and remedial action plans. Specifically, we observed  controls over the FAA Telecommunications Infrastructure (FTI),  Surveillance and Broadcast Service System (SBSS), Traffic Flow  Management-Infrastructure (TFM-I); En Route Automation Modernization  (ERAM); and En Route Communications Gateway. We performed our  work at FAA headquarters in Washington, D.C., and other locations  supporting key systems, specifically: the Air Traffic Control Systems  Command Center in Warrenton, Virginia; the FAA’s William J. Hughes  Technical Center in Egg Harbor Township, New Jersey; and at contractor  facilities in Herndon, Virginia; Egg Harbor Township, New Jersey; and  Melbourne, Florida.
We conducted this performance audit from August 2013 to January 2015  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objective. A full description of our  objective, scope, and methodology can be found in appendix I.
subsections: section_title: Background
paragraphs: The FAA, an agency of the Department of Transportation, is primarily  responsible for the advancement, safety, and regulation of civil aviation,  as well as overseeing the development of the air traffic control system. Its  stated mission is to provide the safest, most efficient aerospace system in  the world. This system, known as the National Airspace System (NAS),  includes air traffic control systems, ATC procedures, operational facilities,  aircraft, and the people who certify, operate, and maintain them.  According to FAA, the system includes more than 19,000 airports, nearly  600 air traffic control facilities, and approximately 65,000 other facilities,  including radar, communications nodes, ground-based navigation aids,  computer displays, and radios, intended to provide safe and efficient flight  services for the public. Over 46,000 FAA personnel and approximately  608,000 pilots operate about 228,000 aircraft within the NAS, including up  to 2,850 flights at any given moment. The system operates on a  continuous basis, 24 hours a day, every day of the year.
As aircraft move across the NAS, controllers at several types of air traffic  control facilities manage their movements during each phase of flight.  According to FAA, these facilities include the following:
More than 500 air traffic control towers supervise flights within about 5  miles from the airport runway. They give pilots taxiing and take off  instructions, air traffic clearance, and provide separation between  landing and departing aircraft.
One hundred sixty Terminal Radar Approach Control facilities provide  air traffic control services for airspace that is located within  approximately 40 miles of an airport and generally up to 10,000 feet  above the airport. These facilities handle sequencing and separation  of aircraft as they approach major metropolitan areas.
Twenty-two Air Route Traffic Control Centers (ARTCC) control and  monitor airplanes over the continental United States and between  airports. Controlling traffic usually at or above 17,000 feet, the typical  center has responsibility for more than 100,000 square miles of  airspace generally extending over a number of states. Three of the  centers also control air traffic over the oceans. Controllers at these  facilities work with pilots to ensure the flight path is smooth and free of  other traffic.
The Air Traffic Control System Command Center manages the flow of  air traffic within the United States. This facility regulates air traffic  when weather, equipment, runway closures, or other conditions place  stress on the national airspace system. In these instances, traffic  management specialists at the command center take action to modify  traffic demands in order to keep traffic within system capacity.
Figure 1 provides a visual summary of air traffic control across the  different phases of flight.
subsections: section_title: Many Networked Information Systems Support NAS Operations
paragraphs: The FAA’s ability to fulfill its mission depends on the adequacy and  reliability of its air traffic control systems, a vast network of computer  hardware, software, and communications equipment. The agency relies  on more than 100 air traffic control systems to process and track flights  around the world. These complex and highly automated systems process  a wide range of information, including radar, weather, flight plans,  surveillance, navigation/landing guidance, traffic management, air-to- ground communication, voice, network management, and other  information—such as airspace restrictions—that is required to support the  agency’s mission. In order to successfully carry out air traffic control  operations, it is essential that these systems interoperate, functioning  both within and across facilities as one integrated system of systems.  According to FAA data available at the time of our review, about one-third  of air traffic control systems rely on Internet Protocol (IP)-based  networking technologies for communication.
FAA’s ongoing effort to modernize the ATC system is referred to as the  Next Generation Air Transportation System (NextGen). NextGen involves  changes to many aspects of air transportation, including the acquisition of  new integrated systems (both software and hardware), flight procedures,  aircraft performance capabilities, and supporting infrastructure to  transform the current air transportation system into one that uses satellite- based surveillance and navigation operations instead of ground-based  radar. These changes are intended to increase the efficiency and  capacity of the air transportation system while maintaining safety and  accommodating anticipated future growth. As demand for the nation’s  increasingly congested airspace continues to grow, NextGen  improvements are intended to enable the FAA to guide and track aircraft  more precisely on more direct routes, reduce delays, save fuel, and  reduce aircraft exhaust emissions.
The following five key air traffic control systems perform critical air traffic  control functions:
FAA Telecommunications Infrastructure (FTI) forms the basic  telecommunications infrastructure for NextGen, replacing the  agency’s legacy networks to provide consolidated telecom services  for the NAS. The FTI is also intended to reduce costs, improve  bandwidth, and offer improved information security services, such as  encryption, so that an enterprise-wide approach to information  security assurance can be achieved.
Surveillance and Broadcast Service System (SBSS) provides  surveillance services to FAA and the aviation community. Most  notably, SBSS provides the Automatic Dependent Surveillance- Broadcast service—one of the six NextGen transformational  programs—which is FAA’s satellite-based successor to radar. This  service makes use of Global Positioning System technology to  determine and share precise aircraft location information, and streams  additional flight information to the cockpits of properly equipped  aircraft.
En Route Automation Modernization (ERAM) replaces the legacy en  route Host computer and backup system, developed more than 40  years ago. According to FAA, much of the system has already been  deployed. ERAM is designed to be at the heart of NextGen and is key  to advancing FAA’s transition from a ground-based system of air  traffic control to a satellite-based system of air traffic management. As  ERAM evolves, it is intended to provide benefits for users and the  flying public by increasing air traffic flow and improving automated  navigation and conflict detection services, both of which are vital to  meeting future demand and preventing gridlock and delays.
En Route Communications Gateway (ECG) is a communications  system that receives data from sources outside the ARTCC, such as  flight plan information and weather data, and passes it to other  systems, including ERAM.
Traffic Flow Management-Infrastructure (TFM-I) provides information  processing support for FAA traffic management personnel as they  coordinate the use of the NAS and respond to conditions of excess  demand. TFM-I receives information on planned and active flights,  generates forecasts of demand up to several hours ahead, presents  this information to Traffic Management Personnel, and provides  automation support for traffic management initiatives to resolve or  ameliorate congestion.
Each of these systems, in conjunction with many others that make up the  NAS computing infrastructure, works to ensure safe flight passageways  for aircraft in U.S. airspace from takeoff to landing.
section_title: Information Security Is Critical to the Nation’s Critical Infrastructures, Including Air Traffic Control Systems
paragraphs: Safeguarding federal computer systems and the systems supporting the  nation’s critical infrastructures, including the NAS, is essential to  protecting national and economic security, and public health and safety.  For government organizations information security is also a key element  in maintaining the public trust. Inadequately protected systems may be  vulnerable to insider threats as well as the risk of intrusion by individuals  or groups with malicious intent who could use their illegitimate access to  obtain sensitive information, disrupt operations, or launch attacks against  other computer systems and networks. Accordingly, since 1997, we have  designated information security as a government-wide high-risk area. In  2003, we expanded this high-risk area to include protecting systems  supporting our nation’s critical infrastructure.those of agency inspectors general, describe persistent information  security weaknesses that place a variety of federal operations at risk of  disruption, fraud, and inappropriate disclosure.
Our previous reports, and  Recent federal guidance demonstrates that securing critical  infrastructures from internal and external threats is a national priority. For  example, in February 2013, the President signed Executive Order 13636,  “Improving Critical Infrastructure Cybersecurity,” to address concerns  about better securing critical infrastructure from cyber threats. This order,  among other things, directed executive branch agencies to promote the  adoption of cybersecurity practices; increase the volume, timeliness and  quality of cyber threat information sharing; incorporate privacy and civil  liberties protections into every initiative to secure critical infrastructure;  and explore the use of existing regulation to promote cybersecurity. The  order also directed the National Institute of Standards and Technology  (NIST) to develop a technology-neutral voluntary framework for improving  critical infrastructure cybersecurity. The framework, issued in February  2014, with business requirements, risk tolerances, and resources.   is designed to help organizations align their cybersecurity activities  Although many legacy air traffic control systems continue to rely on point- to-point communications, NAS systems, including NextGen systems,  increasingly use IP technologies to communicate over interconnected  computer networks. With the increased use of such technologies,  however, comes increased risk: integrating critical infrastructure systems  with information technology networks provides significantly less isolation  from the outside world than predecessor systems, creating a greater need  to secure these systems from remote, external threats.
NIST, Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0  (Gaithersburg, Md.: Feb. 12, 2014).
section_title: Several Organizations within FAA Are Responsible for Information Security
paragraphs: The operational arm of the FAA is the Air Traffic Organization (ATO),  which is responsible for providing safe and efficient air navigation  services to the nation’s airspace. ATO is led by a Chief Operating Officer  who reports directly to the FAA Administrator. The ATO includes seven  service units: Air Traffic, Management, Mission Support, Program  Management Organization, Safety and Technical Training, Systems  Operations, and Technical Operations.
Several entities within ATO share responsibility for information security- related activities over air traffic control systems. The NAS Security Risk  Executive is the individual with overall responsibility for overseeing all  information security-related activities across ATO, including the security  of air traffic control systems. ATO’s Information Security Systems Group,  within Technical Operations Services, includes NAS Cyber Operations  (NCO), ISS Engineering, and an Authorization Team. Ensuring that each  air traffic control system is properly secured and protected is the  responsibility of an Information Systems Security Officer (ISSO), and the  system owner is responsible for planning, directing, and managing  resources for the system, including ensuring that the system meets all  security requirements throughout its life cycle. The Security Risk  Executive, Authorization Team, NCO, system owners, and ISSOs are  jointly responsible for carrying out security program activities for NAS  systems, including conducting system risk assessments, documenting  system security plans, testing security controls, managing remedial action  plans, monitoring and responding to incidents, and planning for  contingencies.
The FAA Office of Information and Technology (AIT) is responsible for the  security of FAA’s non-NAS information systems. The office resides within  FAA’s Office of Finance and Management and is headed by the Chief  Information Officer (CIO), who has overall responsibility to oversee the  security of the agency’s information and information systems. The FAA  Chief Information Security Officer is responsible for developing,  documenting, and implementing an agency-wide information security  program and for assisting the CIO in ensuring compliance with federal law  pertaining to information security and other applicable policies, standards,  requirements and guidelines.
section_title: Requirements for Ensuring the Security of Federal Information Systems Are Established in Law and Guidance
paragraphs: Federal law and guidance specify requirements for protecting federal  information and information systems. The Federal Information Security  Management Act of 2002 (FISMA) requires each agency to develop,  document, and implement an agency-wide information security program  to provide security for the information and information systems that  support operations and assets of the agency, including those provided or  managed by another agency, contractor, or another organization on  behalf of an agency.
FISMA assigns certain responsibilities to NIST, which is tasked with  developing, for systems other than national security systems, standards  and guidelines that must include, at a minimum, (1) standards to be used  by all agencies to categorize all of their information and information  systems based on the objectives of providing appropriate levels of  information security, according to a range of risk levels; (2) guidelines  recommending the types of information and information systems to be  included in each category; and (3) minimum information security  requirements for information and information systems in each category.
NIST, Contingency Planning Guide for Federal Information Systems, SP 800-34,  Revision 1 (Gaithersburg, Md.: May 2010).
NIST, Managing Information Security Risk: Organization, Mission, and Information  System View, SP 800-39 (Gaithersburg, Md.: March 2011).
NIST, Information Security Handbook: A Guide for Managers, SP 800-100  (Gaithersburg, Md.: October 2006). provides guidance for facilitating a more consistent approach to  information security programs across the federal government.
section_title: Security Weaknesses Place Air Traffic Control Systems at Risk
paragraphs: Although FAA has taken steps to safeguard its air traffic control systems,  significant security control weaknesses remain in NAS systems and  networks, threatening the agency’s ability to adequately fulfill its mission.  FAA established policies and procedures for controlling access to NAS  systems and for configuring its systems securely, and it implemented  firewalls and other boundary protection controls to protect the operational  NAS environment. However, a significant number of weaknesses remain  in the technical controls—including access controls, change controls, and  patch management—that protect the confidentiality, integrity, and  availability of its air traffic control systems. Additionally, significant  interconnectivity exists between non-NAS systems and the NAS  operational environment, increasing the risk from these weaknesses.  Further, the agency had not yet fully implemented an agency-wide  information security program to ensure that controls are appropriately  designed and operating effectively. A key reason for both the technical  control weaknesses and the security management weaknesses is that  FAA had not fully established an integrated, organization-wide approach  to managing information security risk that is aligned with its mission.  These shortcomings put NAS systems at increased and unnecessary risk  of unauthorized access, use, or modification that could disrupt air traffic  control operations.
subsections: section_title: FAA Did Not Consistently Control Access to NAS Systems
paragraphs: A basic management objective for any agency is to protect the resources  that support its critical operations and assets from unauthorized access.  An agency can accomplish this by designing and implementing controls  that are intended to prevent, limit, and detect unauthorized access to  computer resources (e.g., data, programs, equipment, and facilities),  thereby protecting them from unauthorized disclosure, modification, and  loss. Specific access controls include boundary protection, identification  and authentication of users, authorization restrictions, cryptography, and  audit and monitoring procedures. Without adequate access controls,  unauthorized users, including intruders and former employees, can  surreptitiously read and copy sensitive data and make undetected  changes or deletions for malicious purposes or for personal gain. In  addition, authorized users could intentionally or unintentionally modify or  delete data or execute changes that are outside of their authority.
Although FAA had issued security policies, it did not consistently protect  its network boundary from possible intrusions; identify and authenticate  users; authorize access to resources; ensure that sensitive data are  encrypted; or audit and monitor actions taken on NAS systems and  networks.
subsections: section_title: Although Control Mechanisms Were Put in Place, FAA Did Not Always Adequately Protect the Boundary of NAS Systems
paragraphs: Boundary protection controls are used to restrict connections into and out  of networks and to control connections between network-connected  devices. Implementing multiple layers of security to protect an information  system’s internal and external boundaries can reduce the risk of a  successful cyber attack. For example, multiple firewalls can be deployed  to prevent both outsiders and insiders from gaining unauthorized access  to systems. NIST Special Publication 800-53 recommends  organizations monitor and control communications both at the external  boundary of the system and at key internal boundaries within the system.  NIST also recommends information systems connect to external networks  or systems only through managed interfaces such as gateways, routers,  or firewalls. FAA policy states that connections between NAS  systems/networks and any non-NAS network or non-NAS information  systems must occur through the NAS Enterprise Security Gateway.
While FAA implemented numerous controls to separate NAS systems  from non-NAS systems, it did not always sufficiently protect connections  between external partners and NAS operational systems or limit  interconnectivity between operational and mission support environments.  The excessive interconnectivity between NAS and non-NAS  environments increased the risk that FAA’s mission-critical air traffic  control systems could be compromised.
section_title: FAA Did Not Consistently Implement Controls for Identifying and Authenticating Users of NAS Systems
paragraphs: Information systems need to be managed to effectively control user  accounts and identify and authenticate users. Users and devices should  be appropriately identified and authenticated through the implementation  of adequate logical access controls. Users can be authenticated using  mechanisms such as a password and user ID combination. NIST SP 800- 53 recommends, and FAA policy requires, strong password controls for  authentication, such as passwords that are at least eight alphanumeric  characters in length, contain at least one upper- and one lower-case  letter, contain numbers and special characters, and expire after a  predetermined period of time.
However, FAA did not consistently implement identification and  authentication controls in accordance with its security policies and NIST  guidance. For example, certain servers and applications supporting NAS  systems did not implement sufficiently strong password controls. As a  result, FAA is at increased risk that accounts could be compromised and  used by unauthorized individuals to access sensitive information or  systems.
section_title: FAA Did Not Always Ensure Users Were Properly Authorized to Access NAS Systems
paragraphs: Authorization encompasses access privileges granted to a user, program,  or process. It is used to allow or prevent actions by that user based on  predefined rules. Authorization includes the principles of legitimate use  and least privilege.implement controls to ensure that only authorized users can access the  system. This includes, but is not limited to, uniquely identifying all users,  periodically reviewing access to the system, disabling accounts that no  longer need access to the system, and assigning the lowest level of  permission necessary for a task. NIST also recommends that systems  and devices be configured so that only the functionality necessary to  support organizational operations is enabled in order to prevent  unauthorized connection of devices, unauthorized transfer of information,  or unauthorized network connectivity.
NIST guidance recommends that organizations  FAA did not always ensure that users’ access to key air traffic control  systems was authorized in accordance with FAA policies and NIST  guidance. In several cases, FAA and its contractors did not properly  document that system users were authorized to access NAS systems.  Additionally, FAA did not always ensure that periodic reviews of user  access to NAS systems were performed in accordance with FAA policies  and NIST guidance. As a result, users of these air traffic control systems  may have greater access than they need to fulfill their responsibilities,  increasing the risk that these systems could be compromised, either  inadvertently or deliberately.
section_title: Sensitive Data Were Not Always Sufficiently Encrypted
paragraphs: Cryptographic controls can be used to help protect the integrity and  confidentiality of data and computer programs by rendering data  unintelligible to unauthorized users and/or protecting the integrity of  transmitted or stored data. Cryptography involves the use of  mathematical functions called algorithms and strings of seemingly  random bits called keys to (1) encrypt a message or file so that it is  unintelligible to those who do not have the secret key needed to decrypt  it, thus keeping the contents of the message or file confidential; (2)  provide an electronic signature that can be used to determine if any  changes have been made to the related file, thus ensuring the file’s  integrity; and (3) link a message or document to a specific individual’s or  group’s key, thus ensuring that the “signer” of the file can be identified.  NIST guidance states that the use of encryption by organizations can  reduce the probability of unauthorized disclosure of information. NIST  Special Publication 800-53 recommends that organizations employ  cryptographic mechanisms to prevent unauthorized disclosure of  information during transmission, encrypt passwords while being stored  and transmitted, and establish a trusted communications path between  users and security functions of information systems. Additionally, when  federal agencies employ cryptography, NIST standards require them to  use Federal Information Processing Standard (FIPS) 140-2-validated  algorithms.
FAA did not always ensure that sensitive data were encrypted when  transmitted or stored, as called for by its policies and NIST guidance. For  example, certain network devices supporting NAS systems did not always  encrypt authentication data when transmitting them across the network,  and other systems did not always encrypt stored passwords using  sufficiently strong encryption algorithms in compliance with FIPS 140-2.  Due to these weaknesses, FAA faces an increased risk that attackers  could compromise accounts or intercept, view, and modify transmitted  data, thereby threatening the confidentiality, integrity, and availability of  the NAS.
section_title: FAA Did Not Consistently Implement Sufficient Audit and Monitoring Controls
paragraphs: Audit and monitoring involves the regular collection, review, and analysis  of auditable events for indications of inappropriate or unusual activity, and  the appropriate investigation and reporting of such activity. Automated  mechanisms may be used to integrate audit monitoring, analysis, and  reporting into an overall process for investigation of and response to  suspicious activities. Audit and monitoring controls can help security  professionals routinely assess computer security, perform investigations  during and after an attack, and even recognize an ongoing attack. Audit  and monitoring technologies include network- and host-based intrusion  detection systems, audit logging, security event correlation tools, and  computer forensics. Network-based intrusion detection systems capture  or “sniff” and analyze network traffic in various parts of a network. FISMA  requires that each federal agency implement an information security  program that includes procedures for detecting, reporting, and responding  to security incidents.
FAA did not consistently implement sufficient audit and monitoring  controls. For example, FAA did not always have sufficient capability to  monitor network traffic or ensure that NAS systems were sufficiently  logging security-relevant events. As a result of these weaknesses, FAA  faces an increased risk that it will be unable to detect and respond to  unauthorized or malicious activities on its systems.
section_title: While Background Investigations Were Conducted in Accordance with Policy, Changes to Network Systems and Software Were Not Always Properly Controlled
paragraphs: In addition to access controls, other important controls should be in place  to ensure the confidentiality, integrity, and availability of an agency’s  information. These controls include policies, procedures, and techniques  for implementing personnel security and securely configuring information  systems. While FAA conducted background investigations in accordance  with its policy, weaknesses in its configuration management processes  increase the risk of unauthorized use, disclosure, modification, or loss of  sensitive information and information systems supporting FAA’s mission.
subsections: section_title: FAA Conducted Background Investigations in Accordance with Policy
paragraphs: Policies related to personnel actions, such as hiring, termination, and  maintaining employee expertise, are important considerations in securing  information systems. If personnel policies are not adequate, an entity runs  the risk of (1) hiring unqualified or untrustworthy individuals; (2) providing  terminated employees opportunities to sabotage or otherwise impair  entity operations or assets; (3) failing to detect continuing unauthorized  employee actions; (4) lowering employee morale, which may in turn  diminish employee compliance with controls; and (5) allowing staff  expertise to decline. Hiring procedures should include contacting  references, performing background investigations, and ensuring that  periodic reinvestigations are consistent with the sensitivity of the position,  in accordance with criteria from the Office of Personnel Management.  FAA policy requires positions to be designated by sensitivity and risk  level, and describes requirements for conducting background  investigations for employees and contractors, including periodic  reinvestigations of individuals in positions of higher risk or sensitivity.
FAA ensured that the employees and contractors we sampled on the  TFM-I, ERAM, SBSS, and FTI programs had appropriate background  investigations. Specifically, all of the employees and contractors we  sampled had up-to-date background investigations that were consistent  with the risk designation of their positions. As a result, FAA reduced its  risk that it has employed or contracted for unqualified or untrustworthy  individuals on these programs.
section_title: FAA Did Not Always Properly Control Changes to Network Devices or Ensure Key Systems Were Fully Patched
paragraphs: Configuration management is an important control that involves the  identification and management of security features for all hardware and  software components of an information system at a given point and  systematically controls changes to that configuration during the system’s  life cycle. Configuration management involves, among other things, (1)  verifying the correctness of the security settings in the operating systems,  applications, or computing and network devices and (2) obtaining  reasonable assurance that systems are configured and operating  securely and as intended. In addition, establishing controls over the  modification of information system components and related  documentation helps to prevent unauthorized changes and ensure that  only authorized systems and related program modifications are  implemented. This is accomplished by instituting policies, procedures,  and techniques that help make sure that all hardware, software, and  firmware programs and program modifications have been properly  authorized, tested, and approved. Patch management, a component of  configuration management, is important for mitigating the risks associated  with software vulnerabilities. When a software vulnerability is discovered,  the software vendor may develop and distribute a patch or work-around to  mitigate the vulnerability. Without the patch, an attacker can exploit the  vulnerability to read, modify, or delete sensitive information; disrupt  operations; or launch attacks against other systems. Outdated and  unsupported software is more vulnerable to attack and exploitation  because vendors may no longer provide updates, including security  updates.
According to NIST SP 800-53, configuration management activities  should include documenting approved configuration-controlled changes to  information systems, retaining and reviewing records of the changes,  auditing those records, and coordinating and providing oversight for  configuration change control activities through a mechanism such as a  change control board. Additionally, NIST Special Publication 800-128states that patch management procedures should define how the  organization’s patch management process is integrated into configuration  management processes, how patches are prioritized and approved  through the configuration change control process, and how patches are  tested for their impact on existing secure configurations. FAA policy  describes detailed requirements for controlling changes to NAS systems.
FAA did not always ensure that changes to network devices supporting  air traffic control systems were managed in accordance with FAA policies  for configuration change control. Specifically, significant changes were  made to a key network device on one NAS system without following the  system’s defined change control process, which requires that changes be  documented, analyzed for potential security impacts, tested, and  approved before being implemented. Without adequately controlling  configuration changes to network devices, an increased risk exists that  changes could be unnecessary, may not work as intended, or may result  in unintentional side effects that could impact mission-critical operations.
Additionally, the agency did not always ensure that security patches were  applied in a timely manner to servers and network devices supporting air  traffic control systems, or that servers were using software that was up-to- date. For example, certain systems were missing patches dating back  more than 3 years. Additionally, certain key servers had reached end-of- life and were no longer supported by the vendor. As a result, FAA is at an  increased risk that unpatched vulnerabilities could allow its information  and information systems to be compromised.
section_title: FAA Did Not Fully Implement Its Information Security Program, Limiting the Effectiveness of Information Security Controls
paragraphs: An entity-wide information security program is the foundation of a security  control structure and a reflection of senior management’s commitment to  addressing security risks. The security program should establish a  framework and continuous cycle of activity for assessing risk, developing  and implementing effective security procedures, and monitoring the  effectiveness of these procedures. Without a well-designed program,  security controls may be inadequate; responsibilities may be unclear,  misunderstood, or improperly implemented; and controls may be  inconsistently applied. FISMA requires each agency to develop,  document, and implement an information security program that, among  other things, includes policies and procedures that (1) are based on risk assessments, (2)  cost-effectively reduce information security risks to an acceptable  level, (3) ensure that information security is addressed throughout the  life cycle of each system, and (4) ensure compliance with applicable  requirements;  security awareness training to inform personnel of information security  risks and of their responsibilities in complying with agency policies  and procedures, as well as training personnel with significant security  responsibilities for information security; periodic testing and evaluation of the effectiveness of information  security policies, procedures, and practices, to be performed with a  frequency depending on risk, but no less than annually, and that  includes testing of management, operational, and technical controls  for every system identified in the agency’s required inventory of major  information systems; a process for planning, implementing, evaluating, and documenting  remedial actions to address any deficiencies in information security  policies, procedures, or practices; procedures for detecting, reporting, and responding to security plans and procedures to ensure continuity of operations for  information systems that support the operations and assets of the  agency.
To its credit, FAA has taken steps to implement an information security  program and manage information security risks for its air traffic control  systems. FAA produced system security plans for the systems we  reviewed which specified the systems’ operational contexts, relationships  with others systems, general security requirements, and security controls.  Additionally, FAA policy requires the periodic testing and evaluation of the  controls on agency systems, and the agency has a process for planning,  implementing, evaluating and documenting remedial actions to address  deficiencies in those controls. FAA also documented a risk assessment  policy and conducted risk assessments on the major systems we  reviewed. However, FAA did not always consistently document incident  response policies, ensure that contractors took required training,  adequately test security controls, mitigate security weaknesses in a timely  manner, ensure that incident response capabilities for NAS systems were  adequate, or fully document and test contingency plans for its air traffic  control systems.
subsections: section_title: Policies and Procedures Were Not Always Complete
paragraphs: A key element of an effective information security program is to develop,  document, and implement risk-based policies, procedures, and technical  standards that govern the security over an agency’s computing  environment. Regarding incident response activities, NIST Special  Publication 800-53 recommends agencies create an incident response  policy and procedures to facilitate the implementation of the policy and  associated incident response controls.
Although FAA had developed and documented many information security  policies and procedures, incident response policies and procedures were  not always complete or approved. For example, although the NCO  security group operates as the focal point for NAS incident response  activities, ATO’s incident response policy establishing NCO as the  incident response focal point was still in draft at the time of our review.
Additionally, although system-level incident response policies had been  finalized for four of the NAS systems we reviewed, they did not always  specify incident reporting timeframes or the need for all incidents to be  reported. Without finalized and harmonized incident response policies,  FAA faces an increased risk that incident response authorities and  responsibilities will not be clearly understood by all stakeholders,  impeding the agency’s ability to efficiently and effectively respond to  incidents or to do so in a timely manner.
section_title: Users with Significant Security Responsibilities Had Not Always Received Required Security Training
paragraphs: According to FISMA, an agency-wide information security program must  include security awareness training for agency personnel, contractors,  and other users of information systems that support the agency’s  operations and assets. This training must cover (1) information security  risks associated with users’ activities and (2) users’ responsibilities in  complying with agency policies and procedures designed to reduce these  risks. FISMA also includes requirements for training personnel who have  significant responsibilities for information security. Additionally, NIST  Special Publication 800-53 recommends that agencies provide incident  response training to information system users consistent with their  assigned roles and responsibilities.
FAA officials were unable to tell us when the policy would be finalized. individuals with significant information system security responsibilities  must receive role-based training specific to their responsibilities. For both  security awareness and role-based training, FAA policy also states that  records must be kept documenting the name and title of the individual  receiving training, their security responsibilities, the type of training  received, and the training date.
However, FAA did not always ensure that its employees and contractors  took required information security training, including specialized security  training and system-specific training, in a timely manner. For example:
FAA contractors supporting certain NAS systems did not take the  required security awareness training.
Additionally, FAA did not provide periodic refresher security training to  individuals with significant security responsibilities on two NAS  systems. Although FAA stated that the Department of Transportation  security awareness training, combined with on-the-job training, was  sufficient, the Department of Transportation training does not cover  security topics specific to these systems, and FAA did not define  required content for on-the-job training or keep training records, as  required by FAA policy.
FAA had also not sufficiently documented that persons with incident  response roles and responsibilities for one of the NAS systems we  reviewed had taken required training, and did not provide formal  incident response training for personnel on another NAS system.
Without adequately ensuring that personnel take required security  training, FAA faces an increased risk that employees may not recognize  and respond appropriately to potential security threats and vulnerabilities.  Further, without sufficiently documenting that incident responders have  taken required training, FAA faces an increased risk that employees will  not receive training on performing their roles and responsibilities on a  regular basis.
section_title: Security Controls Were Not Always Tested Sufficiently
paragraphs: FAA policy, in accordance with NIST guidance, states that security control  assessments are to determine the extent to which controls are  implemented correctly, operate as intended, and produce the desired  outcome with respect to meeting the security requirements of the system.  NIST Special Publication 800-53A notes that while a high-level  examination of a limited body of evidence can support an assessor’s  determination that a control is implemented and free of obvious errors,  determining whether a control is implemented correctly and operating as  intended requires an in-depth analysis of a substantial body of relevant  evidence.
While FAA prepared assessments of the security controls for the NAS  systems we reviewed, its control assessments were not always  comprehensive enough to identify weaknesses that we found in user  account management, configuration management, and security  awareness training controls. For example, FAA concluded that the  account review control for one system was implemented based on  examining the system security plan and interviewing officials, but the  testers did not examine artifacts such as audit reports to determine if  reviews were being conducted as described in the security plan. FAA also  concluded that configuration change control had been implemented for  another system after examining the system security plan and interviewing  personnel; however, artifacts such as change tickets and approval  documents were not examined to determine if system changes were  controlled in accordance with procedures. Further, FAA’s test results  indicated that the security awareness training common control was  defined, but the testers did not examine training records to verify that  personnel on the systems that rely on the control were taking the training  as required. ATO officials stated that control assessments were often  supported by additional documentation not described in the security  control assessment reports; however, the agency was unable to provide  evidence to corroborate this statement.
By not conducting more comprehensive tests of security controls, FAA  has decreased assurance that controls are implemented correctly and  operating as intended. Additionally, because security control  assessments are used by agencies to evaluate whether contractors are  implementing information security controls effectively, FAA had reduced  assurance that its contractors were adequately securing and protecting  air traffic control systems.
section_title: Identified Security Weaknesses Were Not Always Addressed in a Timely Fashion
paragraphs: FISMA requires that agency-wide information security programs include a  process for planning, implementing, evaluating, and documenting  remedial actions to address any deficiencies in the information security  policies, procedures, and practices of the agency. Agencies must  establish procedures to reasonably ensure that all information security  control weaknesses, regardless of how or by whom they are identified,  are addressed through the agency’s remediation processes. For each  identified control weakness, the agency is required to develop and  implement a plan of actions and milestones (POA&M) based on findings  from security control assessments, security impact analyses, continuous  monitoring of activities, audit reports, and other sources. When  considering appropriate corrective actions to be taken, the agency should,  to the extent possible, consider the potential agency-wide implications  and design appropriate corrective actions to systemically address the  deficiency.
While FAA established POA&Ms for addressing identified security control  weaknesses, it did not always complete remedial actions in accordance  with established deadlines. For example, of the 147 POA&Ms we  reviewed on 4 NAS systems, 58 were not completed by their planned  completion dates, and the planned completion dates for 50 had been  extended from between 8 months to more than 3 years past the dates  that they were originally scheduled to be completed. According to ATO  officials, one reason that original deadlines are often missed is that the  programs lack sufficient resources and funding to address weaknesses  by their original due dates. Without resolving identified vulnerabilities in a  timely manner, FAA faces an increased risk, as continuing opportunities  exist for unauthorized individuals to exploit these weaknesses and gain  access to sensitive information and systems.
section_title: NAS Incident Detection and Response Activities Were Limited
paragraphs: Comprehensive monitoring and incident response controls are necessary  for rapidly detecting incidents, minimizing loss and destruction, mitigating  the weaknesses that were exploited, and restoring computing services.  While strong controls may not prevent all incidents, agencies can reduce  the risks associated with these events by detecting and promptly  responding before significant damage is done. NIST Special Publication  800-53 recommends that agencies test incident response capabilities for  effectiveness. NIST guidance also notes that the ability to identify  incidents using appropriate audit and monitoring techniques enables an  agency to initiate its incident response plan in a timely manner. Further,  NIST guidance also recommends that once an incident has been  identified, an agency’s incident response processes and procedures  should provide the capability to correctly log the incident, properly analyze  it, and take appropriate action. NIST guidance also recommends that  agencies test their information technology plans, including incident  response plans, and document the test results in an after action report.  FAA’s ATO assigned responsibility for incident handling on NAS systems  to NCO, although NAS system owners and operators also have a  responsibility to coordinate with NCO in responding to incidents affecting  their systems.
FAA has notable shortcomings in security monitoring and incident  detection over air traffic control systems. For example:
NCO does not have sufficient access to effectively monitor the NAS  operational environment. For example, there was no full network  packet capture and anomaly detection capability for network traffic at  major network interface points at FAA operational facilities.  Additionally, network traffic flow session data was not integrated into  the ad-hoc query systems used by the NCO. Further, NCO lacked  access to data from sensors on key network gateways, including  intrusion detection, network packet capture, and network flow data,  and so cannot adequately monitor the gateways for security-relevant  events.
Although NCO has been given responsibility for incident response for  the NAS environment, 26 of the 35 IP-connected NAS systems did not  provide security event logs to NCO, including 3 of the systems we  reviewed, severely limiting the ability of NCO to effectively monitor the  NAS environment.
The NCO database system containing centralized security logs  collected from various NAS systems was ineffective due to  weaknesses in its searching function. Specifically, the system could  not search past any gaps in the log data. To compensate, NCO  personnel would manually parse the data from multiple queries  together, but there was not sufficient assurance that all data needed  for incident investigations had been retrieved.
NCO did not have a formal process in place to review and document  the potential impact to NAS operations from significant incidents  identified internally or by FAA’s Cyber Security Management Center.  Specifically, NCO did not formally assess the potential risks to the  NAS for any of the incidents we reviewed.
Testing of the NAS incident response capability has been limited.
Specifically, while one system had conducted and documented tests  of its incident response capability, NCO has not developed after- action reports for all phases of its incident response capability tests,  and officials with three systems all indicated they do not test their  incident response capabilities.
As a result, there is an increased risk that FAA will not be able to  adequately detect, contain, eradicate, or recover from incidents affecting  air traffic control systems.
section_title: Contingency Plans Were Not Always Complete or Adequately Tested
paragraphs: Losing the capability to process, retrieve, and protect electronically  maintained information can significantly affect an agency’s ability to  accomplish its mission. If contingency planning controls are inadequate,  even relatively minor interruptions can result in lost or incorrectly  processed data, which can cause financial losses, expensive recovery  efforts, and inaccurate or incomplete information. NIST Special  Publication 800-34 recommends that contingency plans include  procedures for diagnosing and addressing problems, notifying recovery  personnel when the plan needs to be activated, and procedures to be  followed in the event that specific personnel cannot be contacted. NIST  also recommends that contingency plans include procedures for notifying  users when a system has been reconstituted and normal operations have  resumed. Additionally, NIST Special Publication 800-53 notes that  contingency plans should be tested to determine the plan’s effectiveness  and the organization’s readiness to execute the plan.
FAA did not always ensure that contingency plans for air traffic control  systems were complete or that tests of the plans were adequate.  Although FAA documented contingency plans for three systems, it did not  always include important information in these plans. For example, the  contingency plans for two systems did not sufficiently document the  means by which key personnel were to be contacted in the event of a  disaster or define procedures to follow in the event that specific personnel  could not be contacted. Although separate notification procedures were  developed for one of the systems, they were not included in the  contingency plan either explicitly or by reference. Also, although  procedures had been established for notifying users when two of the  systems had been reconstituted and normal operations had resumed, the  contingency plans for those systems did not include or reference the  procedures. Further, the contingency plan for another system did not  contain the actual assessment and recovery procedures for the system.  Also, FAA tested the contingency plans for three NAS systems, but the  tests did not always address key elements of the plans, including  notification procedures, recovering the system on an alternate platform,  and system performance on alternate equipment.
Without including important information in its contingency plans for air  traffic control systems or sufficiently testing its contingency plans, FAA is  at an increased risk of employees or contractors not following the correct  procedures to appropriately recover systems in a timely manner from  service disruptions.
section_title: Inadequate Agency-Wide Information Security Risk Management Processes Contribute to Weaknesses in Security Controls and Security Management
paragraphs: One important reason for many of the weaknesses in security controls as  well as the security program shortcomings identified in our review is that  FAA has not yet fully established an integrated, organization-wide  approach to managing information security risk. According to NIST,  effective risk management requires organizations such as the FAA to  operate in highly complex, interconnected environments using state-of- the-art and legacy information systems—systems that organizations  depend on to accomplish their missions and to conduct important  business-related functions. The complex relationships among missions,  mission/business processes, and the information systems supporting  those missions and processes require an integrated, organization-wide  view for managing risk. Effective management of information security risk  is also critical to the success of organizations in achieving their strategic  goals and objectives.
FISMA requires the head of each federal agency to ensure that  information security management processes are integrated with agency  strategic and operational planning processes. NIST SP 800-39 provides  agencies with guidance for developing and implementing an integrated,  organization-wide program for managing information security risk to  agency operations (i.e., mission, functions, image, and reputation),  organizational assets, individuals, other organizations, and the nation  resulting from the operation and use of federal information systems. It  describes an integrated approach for addressing information security risk  at the organization level, the mission/business process level, and the  information system level. NIST SP 800-39 states that, in managing  information security risk at the organizational level, agencies should  establish and implement information security governance, a risk executive  function, and risk management strategy in order to ensure that risk  management decisions are aligned strategically with the agency’s  missions and business functions consistent with the organizational goals  and objectives. The publication also states that an organization’s  mission/business processes should be designed to manage risk in  accordance with the organizational information security risk management  strategy.
Further, NIST SP 800-100 notes that agencies should have a strategic  plan for information security, which identifies goals and objectives related  to the agency’s mission, specifies a plan for achieving those goals, and  establishes short- and mid-term performance targets and measures that  allow the agency to track manage and monitor its progress towards those  goals and objectives. Also, in February 2014, NIST established its  Framework for Improving Critical Infrastructure Cybersecurity, which  presents a set of industry standards and best practices to help  organizations manage cybersecurity risks to critical infrastructure  systems, and contains a methodology for organizations to evaluate and  strengthen information security programs for critical infrastructure.
While it has taken initial steps, the FAA has not yet implemented an  effective, organization-wide program for managing information security  risk to its mission and operations. Specifically, the FAA Chief Information  Security Officer stated that in November 2013, the agency established a  risk executive function at the agency level in the form of a Cyber Security  Steering Committee. The committee includes representatives from across  FAA, including ATO, NextGen, and FAA’s office of security. However,  FAA has not yet fully established the governance structures and practices  necessary for ensuring that its information security risk management  decisions are aligned strategically with its mission. Specifically:  FAA has not clearly and consistently established roles and  responsibilities for information security for NAS systems. FISMA  requires the head of an agency to (1) ensure that senior agency officials  provide security for information and information systems that support  operations and assets under their control, and (2) delegate to the agency  CIO the authority to ensure compliance with FISMA requirements.  Further, according to NIST Special Publication 800-39, one of the tasks of  the risk executive is to establish risk management roles and  responsibilities. However, existing FAA practices, policies, and  documentation are inconsistent in establishing responsibility for NAS  information security. While FAA’s security management program policy  states that primary responsibility for NAS information security rests with  the CIO, ATO officials stated that primary responsibility for NAS  information security lies with ATO rather than the CIO. FAA’s portion of  the President’s Fiscal Year 2014 Budget Submission states only that the  CIO is responsible for non-NAS systems. The steering committee has  defined updated roles and responsibilities for information security, which  state that executive-level responsibility for the organization-wide  information security program lies with the CIO. However, these roles and  responsibilities have not yet been implemented. Additionally, AIT officials  and ATO officials disagreed about whether the roles and responsibilities  had been approved.
Better defining roles and responsibilities is important because FAA  officials in AIT and ATO expressed diverging opinions about how  information security controls should be implemented in the NAS  environment. For example, AIT officials stated that ATO and AIT should  collaborate to identify and reduce duplicative incident response activities  between NCO and FAA’s existing Cyber Security Management Center,  but ATO officials stated that the NCO capability should remain separate  from the Cyber Security Management Center because of the unique  security requirements of the NAS critical infrastructure.
FAA does not have a strategic plan for information security that is  up to date and reflects current conditions. FAA’s Information Systems  Security Program Policy requires a multiyear information security  strategic plan to be developed, maintained, and updated annually.  Additionally, NIST SP 800-100 states that agencies should revisit the  information security strategic plan when a major change in the agency  information security environment occurs. However, the FAA information  security strategic plan has not been updated since 2010. Significant  changes in the NAS environment, such as the increased reliance on IP  networks, increased connectivity between systems, the introduction of  NextGen systems, and the designation of the NAS as part of the nation’s  critical infrastructure, have changed the level and nature of the  information security risks facing air traffic control systems. The evolution  of connectivity for NAS systems substantially increases risks of Internet- based intrusions and disruptions. AIT officials told us that the Cyber  Security Steering Committee plans to revise the information security  strategic plan during fiscal year 2015.
Because FAA lacks an up-to-date information security strategic plan, the  ATO organization does not have a clear set of goals, objectives, and  performance measures around which it can organize its information  security program. Responsibility for NAS information security in ATO is  distributed across different entities and programs, and ATO officials  stated that variation in emphasis on security goals and priorities across  the organization makes it challenging to manage information security  activities in the NAS environment. For example, according to ATO  officials, the NAS incident response organization, NCO, has limited  capabilities and available staff because it is required to obtain funding  from other program units within ATO, which have different priorities.  Additionally, ATO officials stated that remedial actions are often delayed  because the program units do not hold system owners accountable for  addressing information security weaknesses in a timely manner.
In the absence of clearly defined roles and responsibilities or an updated  strategic plan, ATO has begun moving forward with strategic planning  activities separately from the steering committee’s risk management  responsibilities. During our review, ATO evaluated its information security  processes and capabilities against the guidance in the NIST Framework  for Improving Critical Infrastructure Cybersecurity, with plans to use the  results of the evaluation to develop an information security strategic plan  for ATO. However, other organizations represented on the steering  committee are not involved in this process. Although ATO officials told us  that they plan to inform the members of the committee about the results  of the review, it is not clear whether the committee intends to use the  results in its efforts, or whether ATO’s planned information security  strategic plan will reflect the priorities of FAA as a whole.
Until it fully establishes an integrated, organization-wide approach to  managing information security risk and ensures that federal guidance for  securing critical infrastructure is incorporated into its risk management  processes, FAA is likely to continue to face challenges in ensuring that  risk management decisions are aligned strategically with the its mission  and effectively implementing information security controls for air traffic  control systems. As a result, the weaknesses we identified are likely to  persist.
section_title: Conclusions
paragraphs: A large, complex, interconnected system like the NAS inherently faces  many security risks. Although FAA took many steps to address these  risks, weaknesses remain that challenge the FAA in fulfilling its mission of  ensuring the safety and efficiency of the nation’s airspace operations.  Many weaknesses in access controls and configuration management  pose risks to the security of the NAS. The effect of these weaknesses is  increased by the significant interconnectivity that exists between the FTI  NAS operational environment and the FTI mission support network.  Additionally, significant shortcomings limit NCO’s ability to detect and  respond to security incidents across NAS systems. These weak controls  are mirrored in weak security management processes, such as  incomplete policies and procedures for incident response and insufficient  testing of security controls. Additionally, actions to mitigate identified  security weaknesses are often delayed—sometimes for years. All of  these weaknesses combine to pose increased risks to the confidentiality,  integrity, and availability of NAS systems and thus put the safe and  uninterrupted operation of the nation’s air traffic control system at risk.
A fundamental cause for these various weaknesses is that FAA has not  yet implemented an effective program for managing organizational  information security risk to its mission. Although FAA established a cyber  security steering committee, roles and responsibilities remain unclear,  and AIT and ATO officials continue to disagree on who should be  responsible for the security of NAS systems. Likewise, an out-of-date  information security strategic plan contributes to the lack of an adequate  risk-based structure to guide implementation of security controls. Further,  due in part to the lack of an up-to-date strategic plan for the agency, ATO  lacks a clear set of goals, objectives, and performance measures around  which it can organize its information security program for NAS systems,  making it challenging to manage information security activities such as  ensuring that controls are effectively implemented and that system  owners address identified security weaknesses in a timely manner.
Until FAA establishes stronger agency-wide information security risk  management processes, fully develops its NAS information security  program, and ensures that remedial actions are addressed in a timely  manner, the weaknesses that we identified are likely to continue, placing  the safe and uninterrupted operation of the nation’s air traffic control  system at increased and unnecessary risk.
section_title: Recommendations for Executive Action
paragraphs: To fully implement its information security program and ensure that  unnecessary risks to the security of NAS systems are mitigated, we  recommend that the Secretary of Transportation direct the Administrator  of FAA to implement the following 14 recommendations:
Finalize the incident response policy for ATO and ensure that NAS  system-level incident response policies specify incident reporting  timeframes and the need for all incidents to be reported in accordance  with FAA guidance.
Establish a mechanism to ensure that all contractor staff complete  annual security awareness training as required by federal law and  FAA policy.
Establish a mechanism to ensure that all staff with significant security  responsibilities receive appropriate role-based training.
Establish a mechanism to ensure that personnel with incident  response roles and responsibilities take appropriate training, and that  training records are retained.
Take steps to ensure that testing of security controls is  comprehensive enough to determine whether security controls are in  place and operating effectively, by, for example, examining artifacts  such as audit reports, change tickets, and approval documents.
Take steps to ensure that identified corrective actions for security  weaknesses are implemented within prescribed timeframes.
Provide NCO with full network packet capture capability for analyzing
Provide NCO with access to network sensors on key network  network traffic and detecting anomalies at major network interface  points at FAA operational facilities.  Integrate network traffic flow data into NCO’s ad-hoc query systems.  gateways for reviewing intrusion detection, network traffic, and  network session data.
Provide NCO with security event log data for all IP-connected NAS  systems.
Address identified weaknesses in the search function of the NCO  database event query system to eliminate the need for manual  workarounds and ensure that all data relevant for security  investigations can be retrieved.
Develop a formal process for NCO to assess significant identified  incidents for potential impact to NAS operations.
Ensure that NAS incident response capabilities are adequately tested,  and that test results are sufficiently documented.
Ensure that contingency plans for NAS systems are sufficiently  documented, and that tests of contingency plans address key  elements of the contingency plans, including notification procedures,  recovering the system on an alternate platform, and system  performance on alternate equipment.
Further, to establish an integrated organization-wide approach to  managing information security risk and to ensure that risk management  decisions are aligned strategically with the FAA’s mission, we recommend  that the Secretary of Transportation direct the Administrator of FAA to  take the following three actions:
Clearly define organizational responsibilities for information security  for NAS systems, and ensure that all relevant organizations, including  AIT and ATO, are in agreement with them.
Update the FAA information security strategic plan to reflect current  conditions, including the increased reliance on IP networking and the  designation of the NAS as one of the nation’s critical infrastructures.
Create an agency-wide commitment to strategic planning for  information security by ensuring that planning activities are  coordinated with all relevant organizations represented on the Cyber  Security Steering Committee.
We are also making 168 recommendations to address 60 findings in a  separate report with limited distribution. These recommendations consist  of actions to implement and correct specific information security  weaknesses related to access controls and configuration management.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments (reprinted in appendix II) on a draft of this report, the  Department of Transportation stated that FAA concurred with our  recommendations. The department also stated that FAA recognizes the  need to secure the NAS environment as part of the nation’s critical  infrastructure, and that FAA has taken several steps to improve NAS  information security. Additionally, the department stated that FAA  recognizes that mission assurance requires the integration of all agency  cyber capabilities to support operations and is continuing its efforts to  establish an integrated organization-wide approach to managing  information security risk. We agree that these actions are important steps  for FAA to take, and we also believe that addressing our  recommendations will result in valuable improvements in information  security over air traffic control systems.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to appropriate  congressional committees, the Secretary of Transportation, and other  interested parties. In addition, this report will be available at no charge on  the GAO website at http://www.gao.gov.
Should you or your staffs have questions on matters discussed in this  report, please contact Gregory C. Wilshusen at (202) 512-6244, Dr.  Nabajyoti Barkakati, Ph.D., at (202) 512-4499, or Gerald L. Dillingham,  Ph.D., at (202) 512-2834. We can also be reached by e-mail at  wilshuseng@gao.gov, barkakatin@gao.gov and dillinghamg@gao.gov.
GAO staff who made major contributions to this report are listed in  appendix III.
section_title: Appendix I: Objective, Scope, and Methodology
paragraphs: The objective of our review was to evaluate the extent to which the  Federal Aviation Administration (FAA) has effectively implemented  appropriate information security controls to protect the confidentiality,  integrity, and availability of its existing air traffic control (ATC) systems.
To determine the effectiveness of the FAA’s security controls, we gained  an understanding of the overall National Airspace System (NAS) control  environment and examined controls for the agency’s systems and  facilities. Specifically, we reviewed controls over the network  infrastructure and systems that support the FAA’s mission to provide the  safest, most efficient aerospace system in the world. We performed our  work at FAA headquarters in Washington, D.C. and other locations  supporting key systems, specifically: the Air Traffic Control System  Command Center in Warrenton, Virginia; the FAA’s William J. Hughes  Technical Center in Egg Harbor Township, New Jersey; and at contractor  facilities in Herndon, Virginia; Egg Harbor Township, New Jersey; and  Melbourne, Florida.
To select the information systems for our audit, we evaluated each NAS  information system based on several factors, including its relative  importance in supporting FAA’s mission, expected lifetime, and how  widely it is used. Further, we selected only systems that use Internet  Protocol (IP)-based communications. Based on this evaluation, we   for review: FAA  selected a non-generalizable sample of five systemsTelecommunications Infrastructure (FTI), Surveillance and Broadcast  Service System (SBSS), Traffic Flow Management-Infrastructure (TFM-I),  En Route Automation Modernization (ERAM), and En Route  Communications Gateway (ECG).
GAO, Federal Information System Controls Audit Manual (FISCAM), GAO-09-232G  (Washington, D.C.: February 2009). and procedures; and standards and guidelines from relevant security and  IT security organizations, such as the National Security Agency and the  Center for Internet Security.  reviewed network access paths to determine if boundaries had been  adequately protected;  reviewed the complexity and expiration of password settings to  determine if password management was being enforced; analyzed users’ access authorizations for four systems to determine  whether system access had been approved and properly  documented; observed configurations for transmitting data across the network to  determine whether sensitive data were being encrypted. For the  ERAM and ECG systems, we reviewed configuration settings for  network devices by reviewing the network device builds that are  distributed to Air Route Traffic Control Centers (ARTCC) by the  William J. Hughes Technical Center;  reviewed system security settings to determine if sufficient audit and  monitoring controls had been implemented; evaluated configuration change control processes for selected  systems to determine whether changes were sufficiently documented,  tested, and approved in accordance with system procedures; and  inspected key network devices and servers to determine if critical  patches had been installed and/or were up to date.
Additionally, our review of boundary protection controls focused on  interconnections between NAS and non-NAS systems.
Using the requirements identified by the Federal Information Security  Management Act of 2002, which establishes key elements for an effective  agency-wide information security program, and associated NIST  guidelines and agency requirements, we evaluated the FAA’s information  security program by analyzing processes and documentation that were part of FAA’s  information security risk management processes to determine the  extent to which the process sufficiently supported the agency’s  mission and operations; examining system security plans to determine whether they described  the security controls in place or planned for meeting the security  requirements of the system; examining security awareness training records to determine whether  employees and contractors had received training according to FAA  policy and federal guidance; analyzing security testing and evaluation results for four systems to  determine whether testing of management, operational, and technical  controls was sufficient to conclude that controls were in place and  operating effectively; examining remedial action plans for four systems to determine  whether FAA addressed identified vulnerabilities in a timely manner; examining contingency plans and contingency test results for selected  systems to determine whether those plans were appropriately  documented and had been sufficiently tested; and  reviewing FAA’s processes for identifying and responding to  information security incidents to determine whether FAA has  implemented an effective incident response capability for its air traffic  control systems.
As part of our review of the FAA’s information security program, we  reviewed several sources of computer-generated data. These included  FAA’s employee background investigation data.  inventory of NAS information systems,  IT security training completion data, and  To verify the reliability of these data, we examined them for obvious  outliers, omissions, errors, and consulted with FAA officials to resolve any  identified anomalies. We also interviewed knowledgeable officials  regarding controls on the security training and employee background  investigation data, including how and by whom it is input and used. We  determined that these sources of data were sufficiently reliable for our  purposes.
We conducted this performance audit from August 2013 to January 2015  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objective.
section_title: Appendix II: Comments from the Department of Transportation
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the contacts named above, Gary Austin, Lon Chin, West  Coile, John de Ferrari, Wilfred Holloway, Nick Marinos, and Chris  Warweg (assistant directors); Sher’rie Bacon; Chris Businsky; William  Cook; Saar Dagani; Jennifer Franks; Lee McCracken; John Ockay; Justin  Palk; Krzysztof Pasternak; Monica Perez-Nelson; Eugene Stevens;  Michael Stevens; and Adam Vodraska made key contributions to this  report.