Critical Infrastructure: Challenges Remain in Protecting Key Sectors
Released: 2007-03-20T00:00:00

Letter

Background

Critical Infrastructure Protection Policy Has Emphasized Government and Private Sector Coordination

The protection of the nation’s critical infrastructure against natural and man-made catastrophic events has been a concern of the federal government for over a decade. For example, in May 1998, Presidential Decision Directive 63 (PDD-63) established critical infrastructure protection as a national goal and presented a strategy for cooperative efforts by the government and the private sector to protect it.

In December 2003, HSPD-7 was issued, defining responsibilities for DHS and federal agencies responsible for addressing specific critical infrastructure sectors. These agencies are to identify, prioritize, and coordinate the protection of critical infrastructure to prevent, deter, and mitigate the effects of attacks. DHS is to, among other things, coordinate national critical infrastructure protection efforts, establish uniform policies, approaches, guidelines, and methodologies for integrating federal infrastructure protection and risk management activities within and across sectors; and provide for the sharing of information essential to critical infrastructure protection. According to the NIPP, DHS is also to develop and implement comprehensive risk management programs and methodologies, develop cross-sector and cross-jurisdictional protection guidance, recommend risk management and performance criteria and metrics within and across sectors, and establish structures to enhance the close cooperation between the private sector and government at all levels.

In addition, DHS is the focal point for the security of cyberspace— including analysis, warning, information sharing, vulnerability reduction, mitigation and recovery efforts for public and private critical infrastructure information systems. To accomplish this mission, DHS is to work with other federal agencies, state and local governments, and the private sector. Federal policy further recognizes the need to prepare for debilitating Internet disruptions and—because the vast majority of the Internet infrastructure is owned and operated by the private sector—tasks DHS with developing an integrated public/private plan for Internet recovery.

Sector-Specific Agencies Are to Coordinate Protection Efforts and Develop Plans

HSPD-7 designated sector-specific agencies for each of the critical infrastructure sectors, responsible for coordinating and collaborating with relevant federal agencies, state and local governments, and the private sector, and facilitating the sharing of information about threats, vulnerabilities, incidents, potential protective measures, and best practices. Agencies must submit an annual report to DHS on their efforts. DHS serves as the sector-specific agency for 10 of the sectors: information technology; telecommunications; transportation systems; chemical; emergency services; commercial nuclear reactors, material, and waste; postal and shipping; dams; government facilities; and commercial facilities. (See table 1 for a list of sector-specific agencies and a brief description of each sector).

Under the NIPP, the sector-specific agencies, in coordination with their respective government and private sector councils, are responsible for developing individual protection plans for their sectors that, among other things, (1) define the security roles and responsibilities of members of the sector, (2) establish the methods that members will use to interact and share information related to protection of critical infrastructure, (3) describe how the sector will identify its critical assets, and (4) identify the approaches the sector will take to assess risks and develop programs to protect these assets. DHS is to use these individual plans to evaluate whether any gaps exist in the protection of critical infrastructures on a national level and, if so, to work with the sectors to address these gaps.

Sectors Have Established Government and Sector Councils, Which are Generally Representative of their Sectors; Council Activities Have Varied Depending on Their Maturity and Other Characteristics

All of the sectors have established government councils, and voluntary private sector councils under the NIPP model have been formed for all sectors except transportation systems. The nature of the 17 sectors varies and council membership reflects this diversity, but the councils are generally comprised of representatives from the various federal agencies with regulatory or other interests in the sector, some state and local officials with purview over the sectors, and asset owners and operators. Because some of the councils are newer than others, council activities vary based on the council’s maturity and other characteristics, with some younger councils focusing on establishing council charters, while more mature councils focused on developing protection strategies.

Some Councils Formed in Response to the NIPP, While Others Formed Earlier because of Increased Vulnerabilities

Seven sectors had not formed either a government council or sector council until after publication of an Interim NIPP in February 2005, while 10 of the sectors had done so. These 10 sectors said they recognized the need to collaborate to address risks and vulnerabilities that could result in economic consequences for their sectors. For example, prior to the development of the NIPP, DHS and the Department of Agriculture had (1) established a government coordinating council for the agriculture and food sector to coordinate efforts to protect against agroterrorism, and (2) helped the agriculture and food sector establish a private sector council to facilitate the flow of alerts, plans, and other information. As of March 2007, the transportation systems sector had yet to form a sector council, but a DHS Infrastructure Protection official said each transportation mode— such as rail, aviation, and maritime—had established a sector council. According to DHS officials, once the modes are organized, the transportation systems council will be formed. Transportation Security Administration (TSA) officials attributed the delay to the heterogeneous nature of the transportation sector—ranging from aviation to shipping to trucking.

Council Leaders Believe That Their Memberships Are Generally Representative of Government Agencies with Purview over the Sectors and Are Generally Representative of Asset Owners and Operators

The composition, scope, and nature of the 17 sectors themselves vary significantly, and the memberships of their government and sector councils reflect this diversity. The enormity and complexity of the nation’s critical infrastructure require council membership to be as representative as possible of their respective sectors. As such, council leaders— government sector representatives and private council chairs—believe that their membership is generally representative of their sectors. Government councils include representatives from various federal agencies with regulatory or other interests in the sectors. For example, the chemical sector council includes officials with DHS; the Bureau of Alcohol, Tobacco, Firearms and Explosives; the Department of Commerce; the Department of Justice; the Department of Transportation; and the Environmental Protection Agency because each has some interest in the sector. Some government councils also include officials from state and local governments with jurisdiction over entities in the sector.

Private sector council membership varies, reflecting the unique composition of entities within each, but is generally representative of a broad base of owners, operators, and associations—both large and small—within a sector. For example, members of the drinking water and water treatment systems sector council include national organizations such as the American Water Works Association and the Association of Metropolitan Water Agencies and also members of these associations that are representatives of local entities including Breezy Hill Water and Sewer Company and the City of Portland Bureau of Environmental Services. In addition, the commercial facilities sector council includes more than 200 representatives of individual companies spanning 8 different subsectors, including public assembly facilities; sports leagues; resorts; lodging; outdoor events facilities; entertainment and media; real estate; and retail. This provides the councils opportunities to build the relationships needed to help ensure critical infrastructure protection efforts are comprehensive.

While Newer Councils Are Just Forming, More Mature Councils Are Addressing Long-Term Strategies

Council activities have varied based on the maturity of the councils. Because some of the councils are newer than others, council meetings have addressed a range of topics from agreeing on a council charter to developing industry standards and guidelines for business continuity in the event of a disaster or incident. For example, the commercial facilities government council, which formed in 2005, has held meetings to address operational issues—such as agreeing on a charter, learning what issues are important to the sector, learning about risk management tools, and beginning work on the sector-specific plan. Councils that are more mature have been able to move beyond these activities to address more strategic issues. For example, the banking and finance sector council, which formed in 2002, focused its efforts most recently on strengthening the financial system’s ability to continue to function in the event of a disaster or incident (known as “resilience”), identifying a structured and coordinated approach to testing sector resilience, and promoting appropriate industry standards and guidelines for business continuity and resilience.

Good Prior Working Relationships, Willingness to Share Critical Information, and Sufficient Resources Are Key to Council Formation and Progress

Government and sector council representatives most commonly cited long-standing working relationships between entities within their respective sectors and with the federal agencies that regulate them, the recognition among some sector entities of the need to share infrastructure information with the government and within the sector, and operational support from DHS contractors as factors that facilitated council formation. However, these representatives also most commonly identified several key factors that posed challenges to forming some of the councils, including (1) difficulty establishing partnerships with DHS because of issues including high turnover of its staff and DHS staff who lacked knowledge about the sector to which they were assigned, (2) hesitancy to provide sensitive information or industry vulnerabilities to the government due to concerns that the information might be publicly disclosed, and (3) lack of long-standing working relationships within the sector or with federal agencies.

Recognizing the Need to Work Together; Share Information, and Obtain Support Were Most Common Factors That Helped Facilitate Council Development

One of the factors assisting the formation of many of the government and sector councils was the existence of long-standing working relationships within the sectors and with the federal agencies that regulate them. Ten of the sectors had formed either a government council or private sector council that addressed critical infrastructure protection issues prior to publication of an Interim NIPP. In addition, according to government and sector council representatives, sectors in which the industries have been highly regulated by the federal government—such as the banking and finance sector as well as the commercial nuclear sector—were already used to dealing with the federal government on many issues. Therefore, forming a relationship between the government and the private sector and within the sector was not very difficult.

The availability of DHS contractors that provided administrative and other assistance—such as meeting planning, developing materials, recording and producing minutes, delivering progress reports, and supporting development of governance documents—to the government and sector councils was a third facilitating factor cited by representatives of 13 government and 5 sector councils. For example, representatives of the emergency services sector council and the telecommunications sector council stated that some of the services were very helpful, including guidance the contractors provided on lessons learned from how other sector councils were organized.

Difficulties in Developing Partnerships with DHS, Concerns about Sharing Information, and the Lack of Long-Standing Working Relationships Were the Most Common Challenges to the Formation of Some Councils

Council representatives with three government and eight private sector councils reported that they experienced problems forming their councils due to a number of challenges establishing partnerships with DHS. Specifically, these reported challenges included high turnover of staff, poor communications with councils, staff who were unfamiliar with the sector and did not understand how it works, shifting priorities that affected council activities, and minimal support for council strategies. DHS acknowledged that its reorganization resulted in staff turnover, but according to DHS’s Director of the Infrastructure Programs Office within the Office of Infrastructure Protection, this should not have affected formation since DHS has taken a consistent approach to implementing the partnership model and issuing guidance. However, the director acknowledged that continuing staff turnover could affect the eventual success of the partnerships because they are dependent on the interactions and developing trust. Continuity of government staff is a key ingredient in developing trusted relationships with the private sector.

Representatives with six government and five sector councils noted that the private sector continues to be hesitant to provide sensitive information regarding vulnerabilities to the government as well as with other sector members due to concerns that, among other things, it might be publicly disclosed. For example, these representatives were concerned that the items discussed, such as information about specific vulnerabilities, might be subject to public disclosure under the Federal Advisory Committee Act and thereby be available to competitors or potentially make the council members subject to litigation for failure to publicly disclose any known threats or vulnerabilities.

This issue continues to be a long-standing concern and one that contributed to our designating homeland security information sharing as a high-risk issue in January 2005. We reported then that the ability to share security-related information is critical and necessary because it can unify the efforts of federal, state, and local government agencies and the private sector in preventing or minimizing terrorist attacks. In April 2006, we reported that DHS continued to face challenges that impeded the private sector’s willingness to share sensitive security information with the government. In this report, we assessed the status of DHS efforts to implement the protected critical infrastructure information (PCII) program created pursuant to the Homeland Security Act. This program was specifically designed to establish procedures for the receipt, care, and storage of critical infrastructure information voluntarily submitted to the government. We found that while DHS created the program office, structure, and guidance, few private sector entities were using the program. Challenges DHS faced included being able to assure the private sector that such information will be protected and specifying who will be authorized to have access to the information, as well as to demonstrate to critical infrastructure owners the benefits of sharing the information. We concluded that if DHS were able to surmount these challenges, it and other government users may begin to overcome the lack of trust that critical infrastructure owners have in the government’s ability to use and protect their sensitive information. We recommended that DHS better define its critical infrastructure information needs and better explain how this information will be used. DHS concurred with our recommendations. In September 2006 DHS issued a final rule that established procedures governing the receipt, validation, handling, storage, marking, and use of critical infrastructure information voluntarily submitted to DHS.

Four government and four sector council representatives stated that the lack of prior working relationships either within their sector or with the federal government created challenges in forming their respective councils. For example, the public health and health care sector struggled with creating a sector council that represented the interests of the sector because it is composed of thousands of entities that are not largely involved with each other in daily activities. According to the sector- specific agency representative of the Department of Health and Human Services (HHS), historically, there was relatively little collaboration on critical infrastructure protection-related issues among sector members. Despite these reported challenges, the public health and health care sector has been able to form a sector council that is in the early stages of organization. The commercial facilities sector, which also involves varied and often unrelated stakeholders nationwide, similarly reported that the disparities among stakeholders made forming a council challenging. This sector encompasses owners and operators of stadiums, raceways, casinos, and office buildings that have not previously worked together. In addition, the industries composing the commercial facilities sector did not function as a sector prior to the NIPP and did not have any prior association with the federal government. As a result, this sector council has been concentrating its efforts on identifying key stakeholders and agreeing on the scope of the council and its membership.

Councils Delayed Their Work on Plans until the NIPP Was Issued, but Despite Challenges Submitted Plans to DHS by the Due Date

Each of the 17 sectors provided a sector-specific plan to DHS by the end of December 2006, as required by the NIPP, according to DHS Infrastructure Protection officials. Representatives from both the government and sector councils cited factors that have facilitated the development of their plans—similar to those that facilitated development of their councils— most commonly citing pre-existing plans; historical relationships between the federal government and the private sector or across the private sector, and contractor support. Sector representatives most commonly reported that key challenges in drafting their plans were the late issuance of a final NIPP, which caused some sectors to delay work on their plans, the changing nature of DHS guidance on how to develop the plans, and the diverse make-up of sector membership.

Sector-Specific Agencies Completed Their Plans on Time

Sector-specific agencies met the deadline to complete their plans by December 2006, according to DHS Infrastructure Protection officials. The NIPP requires these plans to contain definitions of the processes the sectors will use to identify their most critical assets and resources as well as the methodologies they will use to assess risks, but not information on the specific protective measures that will be utilized by each sector. The NIPP also requires agencies to coordinate the development of plans in collaboration with their security partners represented by government and sector councils and provide documentation of such collaboration. To date, the level of collaboration between sector-specific agencies and the sector councils in developing the sector-specific plans has varied—ranging from soliciting stakeholder comments on a draft to jointly developing the plan. For example, TSA developed the transportation systems plan and solicited input from private sector stakeholders, while representatives of the energy sector council worked with the Department of Energy to draft the energy plan. Despite these differences, according to DHS Infrastructure Protection officials, all the sectors submitted their plans to DHS by the December 2006 deadline and DHS and other stakeholders are in the process of reviewing them.

Pre-existing Plans, Collaboration, and Contractor Support Were Factors Most Commonly Cited as Facilitating Development of Sector- Specific Plans

Sector representatives from the agriculture and food, banking and finance, chemical, and energy sectors said their sectors had already developed protection plans prior to the interim NIPP published in February 2005 because they had recognized the economic value in planning for an attack. These representatives said they were able to revise their previous plans to serve as the plans called for in the NIPP. For example, the Department of Energy, with input from the sector, had developed a protection plan in anticipation of the Year 2000 computer threat; Department of Energy officials noted that both this plan and the relationships established by its development have been beneficial in developing the protection plan for the energy sector. Similarly, the banking and finance sector council, which worked closely with the Department of Treasury, has had a critical infrastructure protection plan in place for the banking and finance sector since 2003 and planned to use it, along with other strategies, to fit the format required by the NIPP.

Representatives from 13 government and 10 sector councils agreed that having prior relationships—either formally between the federal government and the private sector based on regulatory requirements, or informally within and across industries—facilitated sector-specific plan development. For example, a nuclear sector representative said that its regulator, the Nuclear Regulatory Commission, had already laid out clear guidelines for security and threat response that facilitated developing the sector’s plan. The drinking water and wastewater sector council representative said that its long-standing culture of sharing information and decades of work with the Environmental Protection Agency helped with plan development.

Representatives from seven sector-specific agencies and five sector councils said that assistance from DHS officials or DHS contractors was also a factor that helped with plan development, such as research and drafting. For example, DHS contract staff assisted the Department of the Interior and DHS’s Chemical and Nuclear Preparedness and Protection Division in drafting the plans for the national monuments and icons and emergency services sectors, respectively. Representatives from the chemical, emergency services, nuclear, and telecommunications sector councils said that contractors hired by DHS were helpful as resources providing research or drafting services.

The Late Issuance of a Final NIPP, Changing Guidance, and Other Challenges Impeded Progress on Some Sector- Specific Plans

Representatives from six government councils and six sector councils said that the delays in issuing a final NIPP and changing DHS sector-specific plan guidance contributed to delays in developing their sector plans. According to DHS, sectors had begun drafting their sector-specific plans following the issuance of initial plan guidance in April 2004. But, DHS issued revised guidance based, in part, on stakeholder comments a year later with new requirements, including how the sector will collaborate with DHS on risk assessment processes as well as how it will identify the types of protective measures most applicable to the sector. DHS then issued additional guidance in 2006 requiring that the plans describe how sector-specific agencies are to manage and coordinate their responsibilities. These changes required some sectors—such as dams, emergency services, and information technology—to make significant revisions to their draft plans. Representatives from these sectors expressed frustration with having to spend extra time and effort making changes to the format and content of their plans each time DHS issued new guidance. Therefore, they decided to wait until final guidance was issued based on the final, approved NIPP. In our current work, once we have access to these plans, it will be important to determine how these delays may have affected the quality, completeness, and consistency of the plans.

However, some sectors found the changes in the NIPP and plan guidance to be improvements over prior versions that helped them prepare their plans. For example, representatives from the emergency services sector said that guidance became more specific and, thus, more helpful over time, and representatives from the national monuments and icons sector said that the DHS guidance has been useful. Representatives from the information technology, public health, energy, telecommunications, and transportation systems sectors, among others, had commented that the NIPP should emphasize resiliency—meaning how quickly can a key asset or resource begin operations after an incident—rather than protection measures, such as hiring guards, installing gates and similar actions. According to some of these representatives, it is impossible and cost- prohibitive to try to protect every asset from every possible threat. Instead, industries in these sectors prefer to invest resources in protecting the most critical assets with the highest risk of damage or destruction and to plan for recovering quickly from an event. Representatives from the telecommunications sector added that resiliency is especially important for interdependent industries in restoring services such as communications, power, the flow of medical supplies, and transportation as soon as possible. DHS incorporated the concept of resiliency into the final NIPP to address these concerns and continues to emphasize protection as well.

As in establishing their councils, in developing their sector-specific plans, officials from three government councils and five sector councils said that their sectors were made up of a number of disparate stakeholders, making agreement on a plan more difficult. For example, the commercial facilities sector is composed of eight different subsectors of business entities that have historically had few prior working relationships. According to the government council representative, the magnitude of the diversity among these subsectors has slowed the process of developing a plan so that the sector only had an outline of its plan as of May 2006. Similarly, government and private council representatives of the agriculture and food sector indicated that the diversity of industries included in this sector such as farms, food-processing plants, and restaurants, each of which has differing infrastructure protection needs, has made developing a plan more difficult.

DHS Needs to Fulfill Key Cybersecurity Responsibilities and Address Challenges and GAO Recommendations

To some extent, all sectors depend on cyber infrastructure to operate, such as using computers to control access at nuclear facilities. So, it is important that sectors include cybersecurity in their sector’s protection plan and programs. As the focal point for critical infrastructure protection, DHS has many cybersecurity-related responsibilities that are called for in law and policy. In 2005 and 2006, we reported that DHS had initiated efforts to address these responsibilities, but that more remained to be done. Specifically, in 2005, we reported that DHS had initiated efforts to fulfill 13 key cybersecurity responsibilities (shown in table 2), but it had not fully addressed any of them. For example, DHS established forums to foster information sharing among federal officials with information security responsibilities and among various law enforcement entities, but had not developed national threat and vulnerability assessments for cybersecurity. Since that time, DHS has made progress on its responsibilities—including the release of its NIPP—but none has been completely addressed. Moreover, in 2006, we reported that DHS had begun a variety of initiatives to fulfill its responsibility to develop an integrated public/private plan for Internet recovery, but that these efforts were not complete or comprehensive. For example, DHS had established working groups to facilitate coordination among government and industry infrastructure officials and fostered exercises in which government and private industry could practice responding to cyber events, but many of its efforts lacked time frames for completion and the relationships among its various initiatives are not evident.

DHS faces a number of challenges that have impeded its ability to fulfill its cybersecurity responsibilities, including establishing effective partnerships with stakeholders, achieving two-way information sharing with stakeholders, demonstrating the value it can provide to private sector infrastructure owners, and reaching consensus on DHS’s role in Internet recovery and on when the department should get involved in responding to an Internet disruption. In addition, we reported that DHS faced a particular challenge in attaining the organizational stability and leadership it needed to gain the trust of other stakeholders in the cybersecurity world—including other government agencies as well as the private sector.

In July 2005, DHS undertook a reorganization that established the position of the Assistant Secretary of Cyber Security and Telecommunications—in part to raise the visibility of cybersecurity issues in the department. In September 2006, DHS announced the appointment of an Assistant Secretary for Cyber Security and Telecommunications. Since the appointment, the Assistant Secretary has led efforts to ensure the inclusion of cybersecurity in each critical infrastructure sector’s sector specific plan. The Assistant Secretary has set priorities that include (1) preparing for and deterring attacks by encouraging entities, through implementation of the sector specific plans, to systematically assess their network vulnerabilities and take steps to fix them, (2) responding to cyber attacks of potentially national significance by leveraging operational expertise and building situational awareness and incident response capabilities of the government and private sector; and (3) building awareness about the responsibilities for securing networks across the public and private sectors.

In addition to the National Cyber Security Division, the Assistant Secretary is also responsible for the National Communications System, which ensures continuity of communications and priority service for the government under conditions of national emergency, and the Office of Emergency Communications, established pursuant to the fiscal year 2007 DHS appropriations act. This office is responsible for developing a national strategy and technical assistance and outreach to state and local governments for ensuring operable and interoperable emergency communications capabilities for first responders.

To strengthen DHS’s ability to implement its cybersecurity responsibilities and to resolve underlying challenges, GAO has made about 25 recommendations over the last several years. These recommendations focus on the need to (1) conduct important threat and vulnerability assessments, (2) develop a strategic analysis and warning capability for identifying potential cyber attacks, (3) protect infrastructure control systems, (4) enhance public/private information sharing, and (5) facilitate recovery planning, including recovery of the Internet in case of a major disruption. DHS concurred with most of the recommendations addressed to them. Together, the recommendations provide a high-level road map for DHS to use in working to improve our nation’s cybersecurity posture. While DHS has made progress in addressing some of these recommendations many things remain to be done. Until it addresses these recommendations, DHS will have difficulty achieving results in its role as the federal focal point for the cybersecurity of critical infrastructures— including the Internet. Table 3 shows our detailed recommendations.

Concluding Observations

Critical infrastructure protection is vital to our national security, economic vitality, and public health. Yet a decade after focusing on improving our ability to protect our key assets and resources, progress has been mixed, as Katrina demonstrated. It showed that significant damage to critical infrastructure and key resources could disrupt the functioning of businesses and government alike, underscoring the need for the private and public sector to establish stronger partnerships and working relationships in order to take a coordinated approach to critical infrastructure protection. DHS has moved out by issuing the National Infrastructure Protection Plan as a guiding framework for a national effort, and is providing contractor, technical, and analytical support to sectors, among other things, to encourage progress. Likewise, some sectors—those who are more mature, have been regulated, are more homogeneous, or had economic incentives, such as the threat of Y2K—came together to collaborate, work effectively, and develop protection strategies, even before DHS established the national plan. But other sectors—those who have just been created, who have not worked with federal agencies in the past, who are not regulated but must volunteer to participate in the planning process, and who are large and diverse—face bigger challenges in achieving this coordination and rate of progress. Despite these challenges, each sector submitted a protection plan to DHS. However, DHS has yet to release them. Given the wide variance in the maturity of the sectors, the quality, comprehensiveness, completeness, and consistency of the plans remain to be seen. In addition, it is important to realize that in some cases, the sector specific plan is really more of a first step—a “plan to plan.” In other words, the sectors were only to describe how they expect to identify and prioritize critical assets, how they expect to assess their risks, vulnerabilities, threats and consequences, and how they will approach developing protection programs, not detail how they will implement them.

Thus, fulfilling its statutory responsibilities for ensuring the nation’s critical infrastructure is protected will be a long-term commitment for DHS. This makes it even more important that DHS address challenges that our work has identified over the years and for which we have made a number of recommendations yet to be implemented, including our body of work assessing the protection of cyber infrastructure. These challenges include building trusted working relationships and better collaborating with states and localities, given that the infrastructure is in their communities, as well as the private sector, given that they own most of the assets and resources. Challenges also include providing the environment and incentives for the private sector to voluntarily share information with DHS on gaps in vulnerabilities and protective measures, information that the agency must have to be able to ensure assets and resources critical to the nation are protected. Challenges also include providing organizational stability and leadership, addressing employee turnover and gaps in expertise, and enhancing agency capabilities, such as for providing analysis and warning and identifying and assessing threats and vulnerabilities.

Mr. Chairman, this concludes my statement. I would be pleased to answer any questions that you or other members of the subcommittee may have at any time.

Contact Information

For further information on this testimony, please contact Eileen Larence at (202) 512-8777 or by e-mail at larencee@gao.gov, or regarding cyber- critical infrastructure protection issues, David Powner at (202) 512-9286 or by e-mail at pownerd@gao.gov. Individuals making key contributions to this testimony include Susan Quinlan, Assistant Director; Michael Gilmore; Landis Lindsey; and Edith Sohna.

This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.