Critical Infrastructure Protection: Current Cyber Sector-Specific Planning Approach Needs Reassessment
Released: 2009-10-28T00:00:00

Letter

Sector-Specific Agencies Have Yet to Update Their Respective Sector- Specific Plans to Fully Address Key Cyber Security Criteria as Called for by DHS Guidance

Although DHS reported many efforts under way and planned to improve the cyber content of sector-specific plans, sector-specific agencies have yet to update their respective sector-specific plans to fully address key DHS cyber security criteria. For example, of the 17 sector-specific plans, only 9 have been updated. Of these 9 updates, just 3 addressed missing cyber criteria, and those 3 involved only a relatively small number (3 or fewer) of the criteria in question. Sector-specific agencies did not fully address missing cyber criteria in their plans in large part due to the following: They were focused more on the physical rather than the cyber security aspects of the criteria in preparing their plans.

They were unaware of the cyber criteria shortfalls identified in 2007.

DHS’s guidance on updating sector plans did not specifically request the agencies to update the cyber security aspects of their plans.

The continuing lack of plans that fully address key cyber criteria has reduced the effectiveness of the existing sector planning approach and thus increases the risk that the nation’s cyber assets have not been adequately identified, prioritized, and protected.

Sector Plans and Related Reports Do Not Fully Provide For Effective Implementation

Most sector-specific agencies developed and identified in their 2007 sector plans those actions—referred to by DHS as implementation actions— essential to carrying out the plans; however, since then, most agencies have not updated the actions and reported progress in implementing them as called for by DHS guidance. Specifically, in response to 2006 guidance that called for agencies in developing implementation actions to address three key elements (action descriptions, completion milestones, and responsible parties), most sectors initially developed implementation actions that fully addressed the key elements. However, while 2008 guidance called for implementation actions to be updated and for sector reports to include progress reporting against implementation action milestone commitments, only five sectors updated their plans and reported on implementation progress. DHS attributed this in part to the department not following up and working to ensure that all sector plans are fully developed and implemented in accordance with department guidance. The lack of complete updates and progress reports are further evidence that the sector planning process has not been effective and thus leaves the nation in the position of not knowing precisely where we stand in securing cyber-critical infrastructures.

Conclusions

Although DHS reported many efforts under way and planned to improve the cyber content of sector-specific plans, sector-specific agencies have made limited progress in updating their sector-specific plans to fully address key cyber elements. Further, although the agencies produced narratives on sector activities, they have not developed effective implementation actions and reported on whether progress is being made in implementing their sector plans. This means that as a nation, we do not know precisely where we are in implementing sector plans and associated protective measures designed to secure and protect the nation’s cyber and other critical infrastructure, despite having invested many years in this effort. This condition is due in part to DHS not making sector planning a priority and as such, not managing it in a way that fully meets DHS guidance. These conclusions, taken as a whole, further raise fundamental questions about whether the current approach to sector planning is worthwhile and whether there are options that would provide better results. Consequently, it is essential that federal cyber security leaders— including DHS and the to-be-appointed Cybersecurity Coordinator—exert their leadership roles in this area by, among other things, determining whether it is worthwhile to continue with the current approach as implemented or consider if proposed options provide more effective results. To do less means the nation’s critical infrastructure sectors will continue to be at risk of not being able to adequately protect their cyber and other critical assets or be prepared to identify and respond to cyber threats and vulnerabilities.

Recommendations

We recommend that the Secretary of Homeland Security, consistent with any direction from the Office of the Cybersecurity Coordinator, assess whether the existing sector-specific planning process should continue to be the nation’s approach to securing cyber and other critical infrastructure and, in doing so, consider whether proposed and other options would provide more effective results.

If the existing approach is deemed to be the national approach, we also recommend that the Secretary make it, including the cyber aspects, an agency priority and mange it accordingly. This should include collaborating closely with other sector-specific agencies to develop sector-specific plans that fully address cyber-related criteria in the next release of the plans, and sector annual reports that (1) include updated implementation actions and associated milestones and (2) report progress against plan commitments and timelines.

Agency Comments and Our Evaluation

DHS concurred with our recommendations but took exception with certain report facts and conclusions that it said formed the basis for our recommendations. Specifically, in an email accompanying its written response—which was signed by the Director, Departmental GAO/OIG Liaison Office and is reprinted in appendix II—DHS said it concurred with our recommendation. In its written response, DHS added that it supported continually assessing the effectiveness of the sector approach and identifying and implementing improvements as appropriate. The department also stated in its written response that alternative options can be explored and implemented along with the current sector approach, rather than a binary choice between continuing the existing sector-specific planning approach and other options. We agree such efforts can be pursued in parallel and that doing them in this manner would be consistent with our recommendations. The department also commented that the report does not give due consideration to many of the ongoing sector and cross-sector cyber security activities identified in the annual reports and briefed to us. We recognize that DHS has multiple ongoing efforts to improve critical infrastructure protection (CIP) planning and implementation, and our report conclusions state this point. While our report for the sake of brevity does not include all of DHS’s efforts, it does include illustrative examples throughout as part of giving a fair and balanced view of DHS’s efforts in this area.

Notwithstanding the concurrence discussed above, DHS in its written response took exception with our report’s facts and conclusions in nine areas—referred to by DHS as general items. Each of these general items, along with our response, is summarized below.

General item 1: With regard to our report section that states that the sector-specific agencies have yet to update their respective plans to fully address key cyber security criteria as called for by DHS, the department commented that it established a risk management framework (as part of the 2006 National Infrastructure Protection Plan or NIPP) which called for cyber and other elements (i.e., human, physical) to be addressed. DHS added that its 2006 SSP guidance did not call for these elements to be addressed separately in the plans and at that time GAO had not identified the 30 cyber criteria in DHS’s guidance; therefore, when the 2007 SSPs were issued they did not fully address the 30 cyber criteria (which is consistent with our October 2007 report findings). To address this situation, DHS said it revised the NIPP in early 2009 to, among other things, provide for more robust coverage of cyber security using as a basis the 30 cyber criteria identified by GAO. In addition, in its guidance to the sector agencies in developing their 2010 SSPs, DHS directed the agencies to update their plans using the revised NIPP and in doing so, to fully address the 30 GAO-identified cyber criteria.

GAO response: It is a positive development that DHS has issued guidance directing the sector agencies to fully address missing cyber criteria as part of having the sectors rewrite their SSPs in 2010.

In addition, while we agree with DHS that its 2006 guidance did not call for cyber to be addressed separately in each SSP section, it is important to point out that DHS’s 2006 guidance nonetheless called for the sectors to address in the SSPs how they planned to secure the cyber aspects of their critical infrastructures. Consequently, the 2007 SSPs were to have addressed cyber in order to be in compliance with DHS’s guidance.

In 2007, we initiated a review to assess the extent to which these plans addressed cyber. As part of that review, we analyzed the 2006 guidance and identified 30 cyber-related criteria that the critical infrastructure sectors were to address in their SSPs. Our analysis of the plans found them to be lacking in the cyber area and we subsequently recommended that DHS request that by September 2008, the sector agencies update their SSPs to address missing cyber-related criteria. DHS agreed with this recommendation, and stated that the department had initiated efforts to implement it. However, in following up on this recommendation and analyzing the cyber content of the sectors’ 2008 SSP updates (which was the first objective of this report), only 3 of the 17 sectors had updated their plans to address missing criteria.

General item 2: Regarding the section of our report stating that the reason sector-specific agencies did not fully address missing cyber criteria in their plans was due in part to the fact that they were unaware of the cyber criteria shortfalls identified in our 2007 report, DHS described several initiatives it had taken to inform the agencies of their planning shortfalls.

GAO response: We recognize that DHS has taken actions to inform the agencies of the shortfalls identified in our 2007 report. Accordingly, we cited illustrative examples of such actions throughout our report. Nonetheless, when we interviewed sector agencies officials, several stated that they were unaware of the GAO identified shortfalls, which raises questions about the effectiveness of DHS’s efforts.

General item 3: DHS stated that while the SSPs have not been fully updated to include ongoing and planned cyber security activities, it does not mean there is a lack of cyber security planning in the sectors or that the planning to date has been ineffective. DHS also reiterated its earlier point that our report does not take into account many of its ongoing activities in the sector related to cyber security. In addition, the department commented that all the sectors reported on their progress in the 2008 annual reports.

GAO response: We recognize that DHS has had many ongoing efforts related to improving the cyber content of SSPs and illustrative examples are provided throughout our report. However, the sector-specific agencies’ limited progress in addressing missing cyber content in their SSPs indicates a lack of effectiveness of planning. Specifically, of the 17 sector- specific plans, only 9 have been updated. Of these 9 updates, just 3 addressed missing cyber criteria, and those 3 only involved a relatively small number (3 or less) of the criteria in question. In our view, this continuing lack of plans that fully address key cyber criteria has reduced the effectiveness of the existing sector planning approach and thus increased the risk that the nation’s cyber assets have not been adequately identified, prioritized, and protected.

Further, while we agree with DHS that the sectors reported aspects of progress in the 2008 annual reports, only five sectors updated and reported on the extent of progress in carrying out their implementation actions as called for by DHS guidance, while the other 12 did not. This level of reporting is not sufficient for evaluating sector-wide progress and raises concerns about the effectiveness of these annual reports as a tool to measure progress.

General item 4: DHS commented that (1) we expanded the scope of this engagement beyond the initial focus on coverage of cyber security in the SSPs to encompass the entire sector planning approach and that DHS was not asked to provide a broader update on the public-private partnership, and (2) our draft report did not include information on DHS’s numerous ongoing activities with the agencies and sectors related to cyber security.

GAO response: With regard to the first comment, the focus of our engagement was on the cyber security aspects of the sector-specific plans and progress reporting, which are an important part of the sector planning approach. Consequently, even when taking into consideration DHS’s ongoing activities with the agencies and sectors related to cyber security, the planning and reporting shortfalls we identified indicate a lack of effectiveness with the current sector approach.

Regarding DHS’s second comment, we recognize that DHS has multiple ongoing efforts to improve CIP planning and implementation, and our report includes illustrative examples of DHS’s efforts to do so. As a case in point, on July 27, 2009, we briefed DHS using the presentation slides in this report and updated the slides to incorporate examples (in addition to the ones we had already included in the briefing) that DHS described to us during that meeting. Although DHS has many ongoing efforts related to improving the cyber content of SSPs, our analysis showed that there had been limited progress in addressing missing cyber content in the SSPs since our 2007 recommendation; this indicates to us that the planning process lacks effectiveness, which is why we recommended that DHS assess whether improvements are needed to the current process.

General item 5: In regard to our report stating that DHS guidance calls for the sector agencies to annually review and update as appropriate their sector plans, which serve as a means to provide an interim snapshot of where agencies stand in addressing their gaps and is why we used it as a basis to assess progress, DHS said the SSPs are intended to be strategic, three-year plans and are not meant to provide a snapshot of where agencies stand in addressing their gaps and should not be used as a basis to assess progress in CIP protection.

GAO response: Our report acknowledges that the SSPs are high-level strategic plans and the sector annual reports serve as the primary means of assessing progress in improving CIP protection. Specifically, as stated in our report, the annual reports are used to, among other things, capture changes in sector programs and assess progress made against goals set in the SSPs. However, it should be noted that annual updates to the SSPs also include information on progress being made against SSP goals and as such serve as a source of evidence on where agencies stand in addressing their gaps and provide a basis to assess progress in CIP protection. Specifically, the 2008 updates we reviewed and analyzed included key information on what sector agencies had (or had not) done to address missing cyber security content that we identified in their 2007 SSPs.

General item 6: In response to our reporting that most agencies had not updated their implementation actions and reported progress in implementing them as called for by DHS guidance, DHS commented that many of the implementation actions were one-time actions that were completed in 2007 or 2008, and that others are of an ongoing, continuous nature. The department added that since the vast majority of these items were completed, DHS made adjustments in 2009 to the reporting process to more accurately capture the progress of CIP efforts, and that DHS is now working with the sectors toward the development of outcome-based metrics designed to measure the beneficial value of activities in mitigating CIP risks.

GAO response: We recognize that many of the implementation actions were one-time or ongoing actions, but DHS’s guidance nonetheless called for the sectors to update the actions and report on the extent of progress in achieving the actions. Further, we agree that DHS has made recent positive changes to their reporting processes to more accurately capture progress. However, as noted in our report, most sectors had not reported in their 2008 sector annual reports that their implementation actions were completed, which showed that the existing progress reporting process was not totally effective.

General item 7: In response to our reporting that DHS’s lack of follow up to address SSP planning shortfalls showed it was not making sector planning a priority, the department stated that it (1) is actively engaged with the agencies and sectors, (2) assists the sectors with planning and reporting on an ongoing basis, and (3) continually evaluates and improves these processes with input from the sectors.

GAO response: We recognize that DHS has multiple ongoing efforts to improve CIP planning and implementation, and our report includes illustrative examples of DHS’s efforts. Despite these efforts, DHS’s limited progress in addressing missing cyber content in the SSPs since our 2007 recommendation and the lack of updated implementation actions and progress reporting—coupled with the department’s limited follow up to correct these conditions—led us to conclude that DHS is not making sector planning a priority.

General item 8: DHS stated that although our report cited the work and studies of an expert commission and the President’s cybersecurity working group, including the issues they raised with the current sector planning approach, we did not discuss the reports with the department.

GAO response: On July 27, 2009, we briefed DHS on our findings, conclusions, and recommendations, which included descriptions of the work performed by these two groups. Specifically, in advance of our meeting, we provided the department with a draft of our briefing presentation slides for review and then met to discuss each slide of our presentation, including those addressing the work of these two expert groups.

General item 9: In citing our recommendation that calls for DHS to collaborate closely with the sector-specific agencies to develop SSPs that fully address cyber-related criteria, the department stated this collaboration has already begun as part of the department’s current effort to have the sector agencies update their SSPs for issuance in 2010.

GAO response: This effort to collaborate with the agencies is consistent with our recommendations.

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Should you or your staff have any questions concerning this report, please contact Dave Powner at 202-512-9286 or pownerd@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III.

Appendix I: Briefing Provided to Staff, Subcommittee on Emerging Threats, Cybersecurity, and Science and Technology, House Committee on Homeland Security

Critical Infrastructure Protection: Current Cyber Sector- Specific Planning Approach Needs Reassessment

Attachment I

The nation's critical infrastructure relies extensively on computerized information technology (IT) systems and electronic data. The security of those systems and information is essential to the nation’s security, economy, and public health and safety. To help address critical infrastructure protection, federal policy established a framework for public and private sector partnerships and identified 18 critical infrastructure sectors (e.g., Banking and Finance; Information Technology; Telecommunications; Energy; Agriculture and Food; and Commercial Facilities).

The Department of Homeland Security (DHS) is a key player in these partnerships and is responsible for issuing guidance to direct the sectors to develop plans addressing how key IT systems and data are to be secured, commonly referred to as cyber security.

In June 2006, DHS issued the National Infrastructure Protection Plan (NIPP) as a road map for how DHS and other relevant stakeholders are to enhance the protection of critical infrastructure and how they should use risk management principles to prioritize protection activities within and across the sectors in an integrated, coordinated fashion. Lead federal agencies—referred to as sector-specific agencies—are responsible for coordinating critical infrastructure protection efforts with public and private stakeholders within each sector. For example, the Department of Treasury is responsible for the banking and finance sector while the Department of Energy is responsible for the energy sector.

Further, the NIPP called for the lead federal agencies to develop sector-specific plans and sector annual reports to address how the sectors would implement the national plan, including how the security of cyber and other (physical) assets and functions was to be improved. More specifically, it stated that the sector plans were to, among other things, describe how the sector will identify and prioritize its critical cyber and other assets and define approaches to be taken to assess risks and develop programs to protect these assets; and sector annual reports were to provide status and progress on each sector’s efforts to carry out the sector plans.

In response, the sector-specific agencies developed and issued plans for their sectors in May 2007. Subsequently, in examining these initial plans to determine the extent to which they addressed cyber security, we reported in October 2007, that none of the plans fully addressed all 30 cyber security-related criteria we identified in DHS guidance (in performing that work, we (1) analyzed DHS guidance provided to the critical infrastructure sectors that stated how the sectors should address cyber topics in their sector-specific plans, (2) identified 30 cyber-related criteria, and (3) shared them with responsible DHS officials who largely agreed that these were the correct criteria to use), and recommended that DHS request that by September 2008 the sector-specific agencies’ plans address the cyber-related criteria that were only partially addressed or not addressed at all.

Since then, an expert commission—led by two congressmen and industry officials— studied and reported in late 2008 on the public-private partnership approach, including sector planning and other aspects of U.S cyber security policy.

More recently, the President established a White House cyber security working group that conducted and completed a “60-day” review of U.S. cyber policy, including public- private partnerships and sector planning, that found that while sector and other groups involved in the partnership performed valuable work, there were alternative approaches for how the federal government could work with the private sector and recommended that these options be explored, and recommended, among other things, establishing a Cybersecurity Coordinator’s position within the White House to develop a new U.S. cyber policy and to coordinate cyber security efforts across the federal government. tegic nd InterntionSdie, Securing Cyberspace for the 44th Presidency, A Report of the CSIS Commission on Cybersecurity for the 44th Presidency (Washington, D.C., Decemer 2008); nd The White House, Cyberspace Policy Review: Assuring a Trusted and Resilient Information and Communications Infrastructure (Washington, D.C., My 29, 2009).

As agreed, our objectives were to determine the extent to which sector plans have been updated to fully address cyber assess whether these plans and related reports provide for effective implementation.

For the first objective, we met with the sector-specific agencies to obtain updates to the May 2007 initial plans issued for the 17 critical infrastructure sectors. We then analyzed any updated plans using the 30 cyber criteria we identified in DHS guidance on how such plans were to be developed. Attachment I shows the 30 criteria (organized by eight major reporting sections called for in the DHS guidance). In particular, we focused on assessing the cyber criteria not fully addressed in the May 2007 plans. rrently, there re 18 ector; however, the criticl mctring ector wasablihed in 2008 nd has not yet completed ector-pecific pln.

Objectives, Scope, and Methodology In analyzing the updated plans against the 30 criteria, we categorized the extent to which the plans addressed criteria using the following: fully addressed: the plan specifically addressed the cyber-related criteria partially addressed: the plan addressed parts of the criteria or did not clearly address not addressed: the plan did not specifically address the cyber-related criteria Further, we also interviewed responsible sector-specific agency officials to, among other things, verify our understanding of their updated sector plans and to validate the accuracy of our analyses of the extent to which additional cyber-related criteria had been addressed in them.

For the second objective, we identified requirements in DHS guidance that specified how the sectors were to update and report on their progress in carrying out planned actions—referred to by the department as implementation actions, and compared these requirements to what the sectors had reported in their 2008 annual reports.

We focused on the implementation actions, because they are important for reporting and assessing the progress and effectiveness of the sector-specific plans. Where gaps existed, we collaborated with the sector officials to obtain any additional information that would fulfill the requirements and to determine the cause and impact of any remaining gaps. l mctring ector did not hve ny nnual report.

Although DHS reported many efforts under way and planned to improve the cyber content of sector-specific plans, sector-specific agencies have yet to update their respective sector-specific plans to fully address key DHS cyber security criteria. For example, of the 17 sector-specific plans, only 9 have been updated. Of these 9 updates, just 3 addressed missing cyber criteria, and those 3 involved only a relatively small number (3 or fewer) of the criteria in question. Sector-specific agencies did not fully address missing cyber criteria in their plans in large part due to the following: They were focused more on the physical rather than the cyber security aspects of the criteria in preparing their plans.

They were unaware of the cyber criteria shortfalls identified in 2007, and DHS’s guidance on updating sector plans did not specifically request the agencies to update the cyber security aspects of their plans.

Most sector-specific agencies developed and identified in their 2006 sector plans those actions—referred to by DHS as implementation actions—essential to carrying out the plans; however, since then, most agencies have not updated the actions and reported progress in implementing them as called for by DHS guidance. Specifically, in response to 2006 guidance that called for agencies in developing implementation actions to address three key elements (e.g., action descriptions, completion milestones), most sectors initially developed implementation actions that fully addressed the key elements; however, while 2008 guidance called for implementation actions to be updated and for sector reports to include progress reporting against implementation action milestone commitments, only five sectors updated their plans and reported on progress against implementation actions. DHS attributed this in part to the department not following up and working to ensure that all sector plans are fully developed and implemented in accordance with department guidance.

The lack of complete updates and progress reports is further evidence that the sector planning process has not been effective and thus leaves the nation in the position of not knowing precisely where it stands in securing its cyber and other critical infrastructure. Not following up to address these conditions also shows DHS is not making sector planning a priority. Further, the recent studies by the President’s working group and expert commission also identified shortfalls in the effectiveness of the current public- private partnership approach and related sector planning and offered options for improving the process. Given this, it is essential that DHS determine whether the current process should continue to be the national approach and thus worthy of further investment Accordingly, we are making recommendations to the Secretary of Homeland Security, consistent with any direction from the Office of the Cybersecurity Coordinator, to assess whether the existing sector-specific planning processes should continue to be the nation’s approach to securing cyber and other critical infrastructure. If the existing approach is deemed to be the national approach, we also recommend that the Secretary make it an agency priority and manage it accordingly, including collaborating closely with other sector-specific agencies to develop (1) sector plans that fully address cyber-related criteria and (2) sector annual reports that include implementation actions and milestones and progress reporting against plan commitments and timeline.

In oral and written comments on a draft of this briefing, DHS officials, including the Director of Infrastructure Protection’s Partnership and Outreach Division, which is responsible for sector-specific planning, commented on two areas. Specifically, they stated that that the sector agencies had made more progress in implementing cyber- related criteria than reported in our briefing due to other ongoing DHS and sector efforts outside the sector plans and sector annual reports (implementation actions), which were the focus of the briefing. For example, DHS officials said its cyber division works regularly with many sectors on cyber assessments, exercises, and information sharing. While on the surface these may appear to improve cyber security, the officials did not show how these activities helped the agencies address missing cyber-related criteria or effectively implement their plans. The officials also said that focusing on the agencies’ efforts the year after they issued their sector plans is premature as the agencies have until 2010 to rewrite and reissue their next sector plans. This notwithstanding, DHS’s guidance calls for the sector agencies to annually review and update as appropriate their sector plans, which is a means to provide an interim snapshot of where agencies stand in addressing their gaps and is why we used it as a basis to assess progress.

Consistent with the Homeland Security Act of 2002, Homeland Security Presidential Directive-7 identified DHS as the principal federal agency to lead, integrate, and coordinate implementation of efforts to protect critical infrastructure and key resources; and lead federal agencies, referred to as sector-specific agencies, as responsible for coordinating critical infrastructure protection efforts with the public and private stakeholders in their respective sectors.

It also required DHS to develop a plan that outlines national goals, objectives, milestones, and key initiatives necessary for fulfilling its responsibilities for physical and cyber critical infrastructure protection.

In 2006, DHS issued the plan—commonly referred to as the NIPP—which, in addition to addressing the above, is to serve as a road map for how DHS and other relevant stakeholders are to use risk management principles to prioritize protection activities within and across sectors in an integrated, coordinated fashion. Further, the NIPP required the lead agencies of the 17 critical infrastructure sectors to develop a sector-specific plan (SSP) to address how the sector’s stakeholders would implement the national plan and how each sector would improve the security of its assets systems, networks, and functions.

In addition, as required by the NIPP, the sector-specific agencies are to provide updates on sector progress with their SSPs, including efforts to identify, prioritize, and coordinate the protection of the sector’s critical infrastructure, to DHS on an annual basis. DHS is responsible for incorporating these reports into an overall critical infrastructure/key resources report, called the National Critical Infrastructure/Key Resources Protection Annual Report, which is due to the Executive Office of the President by September of each year.

Sector-specific agencies are to work in coordination with relevant government and private-sector representatives to develop and update the SSPs. Table 1 shows the designated agency for each sector.

The sector-specific plans are to describe how the sector will identify and prioritize its critical assets, including cyber assets such as networks; identify the approaches the sector will take to assess risks and develop programs to manage and mitigate risk; define the security roles and responsibilities of members of the sector; and establish the methods that members will use to interact and share information related to the protection of critical infrastructure.

In response, the sector-specific agencies developed and issued SSPs for their sectors in May 2007. Subsequently, we examined these plans to determine the extent to which they addressed cyber security and reported in October 2007 on the extent to which the sectors addressed aspects of cyber security in their plans. Specifically, we reported that the results varied in that none of the plans fully addressed all 30 cyber security-related criteria. We also reported that several plans—including the information technology and telecommunications sectors—fully addressed many of the criteria and others—such as agriculture and food and commercial facilities—were less comprehensive.

Further, we recommended that DHS request that by September 2008 the sector-specific agencies’ plans address the cyber-related criteria that were only partially addressed or not addressed at all. In its October 2007 response to our report, DHS agreed with our recommendation and stated it had initiated actions to implement it.

Since our 2007 report, an expert commission (led by two congressmen and industry officials) and a White House working group (established by the President) studied and reported on the public-private partnership approach and related issues such as sector planning as well as other aspects of U.S cyber security policy. Specifically, In August 2007, a commission—commonly referred to as the Commission on Cybersecurity for the 44th Presidency—was established to examine the (1) adequacy of U.S. cyber strategy, including public-private partnerships and the sector approach and (2) identify areas for improvement. In December 2008, the commission reported, among other things, that the current public-private partnership and sector planning approach had serious shortcomings such as overlapping roles and responsibilities and duplication of effort. The commission made 25 recommendations aimed at addressing these and other shortfalls with the strategy and its implementation. tegic nd InterntionSdie, Securing Cyberspace for the 44th Presidency, A Report of the CSIS Commission on Cybersecurity for the 44th Presidency (Washington, D.C., Decemer 2008); nd The White House, Cyberspace Policy Review: Assuring a Trusted and Resilient Information and Communications Infrastructure (Washington, D.C., My 29, 2009).

In February 2009, the President directed the National Security Council and the Homeland Security Council to conduct a comprehensive “60-day review” of all U.S. cyber policies and structures. With regard to public-private partnerships, which include sector planning, the councils reported in May 2009 that the sector and other groups involved in this area performed valuable work but that there was a proliferation of plans and recommendations that resulted in government and private sector personnel and resources being spread across a multitude of organizations engaged in sometimes duplicative or inconsistent efforts. The review concluded that there are alternative approaches for how the federal government can work with the sectors and recommended that these options be explored. At this time, the President also created the office of Cybersecurity Coordinator—who is to be part of the White House’s National Security Staff and National Economic Council—to, among other things, assist in developing a new U.S. cyber policy. The Cybersecurity Coordinator position has not yet been filled.

Sector-Specific Agencies Have Yet to Update Their Respective Sector-Specific Plans to Fully Address Key Cyber Security Criteria as Called for by DHS Guidance In response to our recommendation and as part of ongoing DHS efforts, the department initiated multiple efforts to improve the cyber content of their SSPs. Examples include the following: February 2008, DHS invited all sectors (and nine accepted) to meet with cyber experts within DHS’s National Cyber Security Division to support the development of increased cyber content in SSPs.

April 2008, DHS issued guidance to agencies on how to report on the progress of annual reviews of the SSPs.

March 2009, DHS released guidance that specifically requested that agencies, as a part of their 2010 SSP rewrites, fully address all cyber-related weaknesses, including those identified in our October 2007 report.

23 having personnel from its Software Assurance Program work with public and private sector partners to develop a process for identifying exploitable software before security breaches occur.

However, despite these steps, only 9 of the 17 SSPs have been updated while 8 have not.

In addition, of the 9, only 3 have been revised to address missing cyber-related criteria, and those changes only involved addressing a relatively small number (3 or fewer) of missing criteria. Specifically: In developing the original Chemical sector SSP, DHS had fully or partially addressed 29 criteria but did not address 1. The current version of the SSP fully addressed 1 of the criteria previously assessed as partial.

In developing the original Commercial Facilities sector SSP, DHS had fully or partially addressed 20 criteria and did not address 10. The current version of the SSP fully addressed 1 cyber-related criterion that was previously not addressed and partially addressed 1 cyber-related criterion that was previously not addressed. ly inclde 17 of the 18 ector, as the Criticl Mctring ector wasablihed in 2008 nd has not yet finihed it ector-pecific pln. ire SSP to e revied nd reissued every three ye, it o cll for the ector-pecific gencie to nnually review nd pdte as pproprite their SSP to reflect progress on ction plnned nd nder wy. The gidnce llow gencie the option to report progress vi pdted pln, lit of pdte, or in the case there i no progress to report, memorndm of no ction. Thee 8 were memorndm of no ction.

In developing the original Water sector SSP, the Environmental Protection Agency had fully or partially addressed 29 criteria and did not address 1. The current version of the SSP fully addressed 1 cyber-related criterion that was not previously addressed and fully addressed 2 cyber-related criteria that were previously partially addressed.

Figure 1 summarizes the extent to which each SSP update addresses the 30 criteria.

The sector-specific agencies did not fully address missing cyber-related criteria in their SSP updates in large part due to the following: Agency officials said that in developing their plans, they were focused more on specific (physical) threats to the sector than the cyber security aspects.

While DHS began efforts to improve the cyber content of SSPs, sector agency officials stated that DHS did not make them aware of the specific cyber criteria shortfalls we identified and reported on in 2007.

While DHS issued SSP (formatting) guidance in 2008, this guidance did not specifically request updates to cyber security aspects of the plans or provide other substantive-type direction.

As previously stated, DHS issued guidance in March 2009 that specifically requested that the sectors address cyber criteria shortfalls in their 2010 sector-specific plan revisions. However, until these plans are issued, it is not clear whether they fully address cyber requirements. This notwithstanding, having sector-specific agencies continue to have SSPs that do not fully address key cyber elements has reduced the effectiveness of the existing sector planning approach and thus increases the risk that the nation’s critical cyber assets have not been adequately identified, prioritized, and protected.

Sector Plans and Related Reports Do Not Fully Provide for Effective Implementation To provide for effective sector plan implementation, DHS issued guidance that called for the sector-specific agencies to provide for such activities in their SSPs and sector annual reports.

Specifically, with regard to the SSPs, the department issued March 2006 guidance directing the sector-specific agencies to develop and incorporate in their SSPs actions and activities—referred to as implementation actions—essential to carrying out the plans and achieving the goal of securing the sectors’ cyber and other assets. According to the guidance, implementation actions are to include (1) a description of the actions necessary to implement the plan, (2) milestones for when the actions are to be accomplished, and (3) the parties responsible for managing and overseeing action execution. Developing and updating implementation actions, including milestones, and responsible parties, is important for reporting and assessing the progress and effectiveness of the sector- specific plans.

With regard to sector annual reports, the department issued guidance in March 2008 that called for sector-specific agencies (in their 2008 annual reports to be issued later in 2008) to (1) update implementation actions, and (2) report on the extent of progress in achieving the actions. idnce, DHS refer to thection as n implementtion mtrix.

Of the 17 SSPs developed in response to DHS’s guidance, 14 included implementation actions that addressed all three elements: o Banking and Finance, o Chemical, o Commercial Facilities, o Dams, o Defense Industrial Base, o Emergency Services, o Government Facilities, o Information Technology, o National Monuments and Icons, o Nuclear Reactors, o Public Health and Healthcare, o Telecommunications, o Transportation, and o Water. 2 included implementation actions but each only partially addressed the three o Energy, and o Postal and Shipping. rrently, there re 18 ector; however, the criticl mctring ector wasablihed in 2008 nd has not yet completed ector-pecific pln.

Of these sectors’ plans, all identified actions and milestones critical to implementation of the plan but did not identify the parties responsible for the specified actions. 1 did not include implementation actions: o Agriculture and Food.

In addition, with regard to sector annual reporting, 5 sectors updated and reported on the extent of progress in carrying out their implementation actions, while the other 12 did not. Those that did were o Dams, o Information Technology, o National Monuments and Icons, o Nuclear Reactors, and o Water. l Mctring ector was not reqted to develop nnual report, as the ector wasablihed in erly 2008. tion ction were pdted in one re covered nder the Ncler Rector ector.

Those that did not were o Agriculture and Food, o Banking and Finance, o Chemical, o Commercial Facilities, o Defense Industrial Base, o Emergency Services, o Energy, o Government Facilities, o Postal and Shipping, o Public Health and Healthcare, o Telecommunications, and o Transportation.

Figure 2 shows by sector, each sector’s progress in developing and updating actions for effective implementation.

In addition to these implementation actions, the sectors were to report on sector goals and priorities, sector programs, sector coordination, research and development progress and gaps, funding priorities, sector security practices, and overall progress of critical infrastructure protection efforts. However, these areas, including overall progress, did not specifically address implementation progress with the sector- specific plan. For example, the energy sector reported on, among other things, progress with communicating with sector partners, protecting international energy assets, and collaborations with the Department of Homeland Security. In addition, the communications sector reported on, among other things, progress to narrow key gaps identified in the sector’s 2007 report, and progress with key programs. Despite this, the reporting was not sufficient for evaluating either sector-wide progress with sector-specific plans, or the effectiveness of these plans.

The incomplete implementation updates and progress reports are due in part to DHS not following up and working to ensure that all sector plans were fully developed and implemented in accordance with departmental guidance. Specifically, although DHS issued periodic sector-planning guidance, periodically met with sectors officials, and conducted other planning-related activities as discussed above, department officials said their follow-up and oversight of the sector plans did not always result in the sectors developing plans that fully meet DHS guidance. These officials said this occurs due to the fact that as part of DHS’s partnership with the private sector, the parties do not always agree on the extent to which DHS guidance is to be addressed in performing sector planning activities. Consistent with this, our past cyber critical infrastructure protection research and extensive experience at the sector agencies and their private sector counterparts have shown that the public-private partnership is indeed challenging to manage. That research and work also pointed out that DHS nonetheless has a leadership role and responsibility to make sure (1) the partnership works effectively and (2) the sectors plan for and implement efforts aimed at protecting the nation’s cyber and other critical infrastructure, including ensuring the current sector approach is still worth pursuing and considering, where appropriate, alternative approaches. mple, GAO, Critical Infrastructure Protection: Department of Homeland Security Faces Challenges in Fulfilling Cybersecurity Responsibilities, GAO-05-434, (Washington, DC.: My 26, 2005); nd Critical Infrastructure Protection: Progress Coordinating Government and Private Sector Efforts Varies by Sectors' Characteristics, GAO-07-39, (Washington, DC.: Oct. 16, 2006).

Shortfalls with Current Public-Private Partnership Approach and Related Sector Planning Highlighted in Recent Studies by Expert Commission and Presidential Working Group In addition to the above briefing results, the recent reports by the Commission on Cybersecurity for the 44th Presidency and President’s 60-day review also identified shortfalls with the current public-private partnership approach and relating sector planning, that show such planning is not effective. To address the shortfalls, the commission and presidential review identified options to be considered as means to improving sector planning. Examples include: The cyber security commission recommended simplifying the sector approach by prioritizing sectors in order to focus planning and other activities on the most important sectors—which it identified as Energy, Finance, Information Technology, and Communications—with the most important cyber assets.

The President’s review identified a number of models of effective public-private partnership and planning (e.g., the processes and structures used by the United Kingdom) and suggested that the positive attributes of these models be applied to the sector agencies and related organizations. It also recommended streamlining existing sector and others organizations involved in the partnerships to optimize their capacity to identify priorities and develop response plans.

Accordingly, we recommend that the Secretary of Homeland Security, consistent with any direction from the Office of the Cybersecurity Coordinator, assess whether the existing sector-specific planning processes should continue to be the nation’s approach to securing cyber and other critical infrastructure and, in doing so, consider whether proposed and other options would provide more effective results.

If the existing approach is deemed to be the national approach, we also recommend that the Secretary make it, including the cyber aspects, an agency priority and manage it accordingly. This should include collaborating closely with other sector-specific agencies to develop sector-specific plans that fully address cyber-related criteria in the next release of sector annual reports that (1) include updated implementation actions and associated milestones and (2) report progress against plan commitments and timelines.

41 Agency Comments and Our Evaluation In oral and written comments on a draft of this briefing, the Director of Infrastructure Protection’s Partnership and Outreach Division and other department officials commented on the following two areas: First, they stated that that they believed that the sector agencies had made more progress in implementing cyber-related criteria than reported in our briefing due to other ongoing DHS and sector efforts outside the SSPs and sector annual reports (implementation actions), which were the focus of the briefing. For example, DHS officials said its National Cyber Security Division works regularly with many sectors on cyber assessments, exercises, and information sharing. In addition, DHS cites two cross-sector cyber working groups that play an important role in advancing cyber security. While these and the other examples provided by DHS on the surface appear to improve cyber security, DHS officials did not show how these activities helped the agencies address missing cyber-related criteria in their SSPs or effectively implement their plans. 42 Agency Comments and Our Evaluation Second, the officials stated that focusing on the agencies’ efforts the year after they issued their sector plans is premature as the agencies have until 2010 to rewrite and reissue their next sector plans. While the NIPP calls for the next SSPs to be issued in 2010, it also calls for the sector-specific agencies to annually review and update as appropriate their SSPs, which is a means to provide an interim snapshot of where agencies stand in addressing their gaps and is why we used it as a basis to assess agency progress.

DHS officials also provided technical comments, which we have incorporated into the briefing as appropriate.

Attachment I: DHS’s Cyber Criteria Organized by Major Reporting Sections

Section 7: Critical Infrastructure Protection Research and Development (R&D)

Appendix II: Comments from the Department of Homeland Security

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, the following staff also made key contributions to this report: Gary Mountjoy, Assistant Director; Scott Borre; Rebecca Eyler; Lori Martinez; and Teresa Smith.