Critical Infrastructure Protection: Significant Challenges in	 
Developing National Capabilities (25-APR-01, GAO-01-323).	 
								 
To address concerns about protecting the nation's critical	 
computer-dependent infrastructures from computer-based attacks	 
and disruption, the President issued Presidential Decision	 
Directive (PDD) 63 in 1998.  A key element of the directive was  
the establishment of the National Infrastructure Protection	 
Center as a national focal point' for gathering information on	 
threats and facilitating the federal government's response to	 
computer-based incidents. To determine how effectively the center
has fulfilled its role, the GAO evaluated the center's progress  
in (1) developing national capabilities for analyzing cyber	 
threat and vulnerability data and issuing warnings, (2) enhancing
its capabilities for responding to cyber attacks, and (3)	 
developing outreach and information-sharing initiatives with	 
government and private-sector entities. GAO found that although  
the center has taken some steps to develop analysis and warning  
capabilities, the strategic capabilities described in PDD 63 have
not been achieved. The center has provided important support in  
increasing the Federal Bureau of Investigation's ability to	 
investigate computer crimes by coordinating investigations and	 
providing technical assistance, and also has developed crisis	 
management procedures and drafted an emergency law enforcement	 
sector plan, which is now being reviewed by sector members. The  
center's information-sharing relationships are still evolving and
will probably have limited effectiveness until reporting	 
procedures and thresholds are defined and trust relationships are
established.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-323 					        
    ACCNO:   A00876						        
  TITLE:     Critical Infrastructure Protection: Significant	      
             Challenges in Developing National Capabilities                   
     DATE:   04/25/2001 
  SUBJECT:   Computer crimes					 
	     Computer security					 
	     Information resources management			 
	     Interagency relations				 
	     Performance measures				 
	     Terrorism						 
	     DOJ Five-Year Interagency				 
	     Counterterrorism and Technology Crime		 
	     Plan						 
								 
	     DOJ InfraGard Information-Sharing			 
	     Program						 
								 
	     NIST Federal Computer Incident Response		 
	     Capability Program 				 
								 

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GAO-01-323
     
A

Report to the Subcommittee on Technology, Terrorism, and Government
Information, Committee on the Judiciary, U. S. Senate

April 2001 CRITICAL INFRASTRUCTURE PROTECTION

Significant Challenges in Developing National Capabilities

GAO- 01- 323

Letter 5 Executive Summary 8 Chapter 1

22 Introduction

Cyber Risks to Critical Infrastructures Are Substantial and Increasing 22
Concern About Critical Infrastructure Protection Has Been Growing 25 PDD 63
Outlined a National Critical Infrastructure Protection Strategy 27 The NIPC
Is Assigned A Broad Set Of Responsibilities 29 Objectives, Scope, and
Methodology 32

Chapter 2 35

Multiple Factors Limit PDD 63 Directs the NIPC to Develop Analysis and
Warning

Capabilities 36 Progress in Developing Analyses Have Primarily Supported
Investigations of Individual National Analysis and

Incidents 37 Warning Capabilities

The NIPC Has Developed a Rudimentary Warning Capability 42 Other Factors
Impeding Development of Analysis and Warning

Capabilities 49 Conclusions 56 Recommendations for Executive Action 57
Agency Comments and Our Evaluation 58

Chapter 3 60

The NIPC Has The NIPC Has Provided Coordination and Technical Support to

FBI Field Squads 60 Provided Valuable Increase in Computer Crime Cases Has
Prompted the Need for Support and

Increased Coordination and Technical Support 61 Coordination in Crisis
Management Plans Have Been Developed 66

Requirements for Monitoring Reconstitution Have Not Been Defined 67
Improving Conclusions 68 Investigation and Recommendations for Executive
Action 68

Agency Comments and Our Evaluation 69 Response Capabilities

Chapter 4 71

Progress In Information Sharing And Coordination Are Essential To Combat

Cyber Attacks, But Present Challenges 72 Information Sharing Information-
sharing Success With Private Sector Has Varied 73 And Outreach Has

Information Sharing and Coordination With Other Government Been Mixed

Entities Have Been Limited 80 Conclusions 85 Recommendations for Executive
Action 85 Agency Comments and Our Evaluation 86

Chapter 5 88

Funding Used For a The FBI Provided Funds to the NIPC on the Basis of
Congressional Direction and NIPC Requirements 89

Variety of NIPC- related Funds Primarily Used to Support The NIPC 92
Activities

Conclusions 95 Agency Comments 95

Appendixes Appendix I: Comments From the National Infrastructure Protection
Center 96

Appendix II: Comments From the National Security Council 102 Tables Table 1:
Warnings Issued by the NIPC, 1998, 1999 and 2000 44

Table 2: Computer Crime Cases From FY 1998 to FY 2000 (all numbers are as of
October 1) 61 Table 3: Personnel Trained by the NIPC From May 1998 Through

August 2000 84 Table 4: Fiscal Year 1999 NIPC Funding Specified in
Congressional

Conference Report 89 Table 5: Fiscal Year 2000 NIPC Funding Specified in
Congressional

Conference Report 90 Table 6: Fiscal Year 1999 Funding Provided to the NIPC
From the FBI 91

Table 7: Fiscal Year 2000 Funding Provided to the NIPC From the FBI 91 Table
8: Amounts Obligated by the NIPC During Fiscal Years 1999

and 2000 93 Figures Figure 1: Risks to Computer- Based Operations 23

Figure 2: Critical Infrastructure Protection Responsibilities, as Outlined
by PDD 63 28 Figure 3: NIPC Organizational Chart 32

Abbreviations

AISU Analysis and Information Sharing Unit CERT/ CC Computer Emergency
Response Team Coordination Center CIA Central Intelligence Agency DOD
Department of Defense EPA Environmental Protection Agency FBI Federal Bureau
of Investigation FedCIRC Federal Computer Incident Response Capability FEMA
Federal Emergency Management Agency GSA General Services Administration HHS
Department of Health and Human Services ISAC Information Sharing and
Analysis Center NIPC National Infrastructure Protection Center OMB Office of
Management and Budget OSTP Office of Science and Technology Policy PDD
presidential decision directive SANS Systems Administration, Networking, and
Security Institute

Lett er

April 25, 2001 The Honorable Jon Kyl Chairman The Honorable Dianne Feinstein
Ranking Member Subcommittee on Technology, Terrorism, and Government
Information Committee on the Judiciary United States Senate

The Honorable Charles E. Grassley United States Senate

In response to your request of May 16, 2000, this report describes the
progress of the National Infrastructure Protection Center (NIPC) in (1)
developing national capabilities for analyzing cyber threat and
vulnerability data and issuing warnings, (2) enhancing its capabilities for
responding to cyber attacks, and (3) developing outreach and information-
sharing initiatives with government and

private- sector entities. In addition, we were asked to determine the
purposes for which the NIPC used funding provided for fiscal years 1999 and
2000.

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
the date of this letter. At that time, we will send copies to other
interested congressional committees; the Honorable Condoleezza Rice,
Assistant to the President for National Security Affairs; the Honorable John
Ashcroft, Attorney General; the

Honorable Louis Freeh, Director of the Federal Bureau of Investigation; and
the Honorable Mitchell E. Daniels, Jr., Director of the Office of Management
and Budget. The report will also be available on GAO?s Web site at www. gao.
gov. If you or your offices have any questions about matters discussed in
this report, please call me at (202) 512- 3317 or Jean Boltz, Assistant
Director, at (202) 512- 5247. We can also be reached by e- mail at daceyr@
gao. gov and boltzj@ gao. gov, respectively. Major contributors to this
report include

Michael Gilmore, Rahul Gupta, Danielle Hollomon, William McDaniel, Paul
Nicholas, Patrick Sullivan, and Thomas Wiley.

Robert F. Dacey Director, Information Security Issues

Executive Summary Purpose To address concerns about protecting the nation?s
critical computerdependent infrastructures from computer- based attacks and
disruption, in

1998, the President issued Presidential Decision Directive (PDD) 63. A key
element of the strategy outlined in that directive was establishment of the
National Infrastructure Protection Center (NIPC) as ?a national focal point?
for gathering information on threats and facilitating the federal
government?s response to computer- based incidents. To determine how

effectively the NIPC has fulfilled its role, the Subcommittee on Technology,
Terrorism, and Government Information, Senate Committee on the Judiciary,
asked that GAO evaluate the progress the NIPC has made in (1) developing
national capabilities for analyzing threat and vulnerability data and
issuing warnings; (2) enhancing its capabilities for responding to cyber
attacks; and (3) developing outreach and information- sharing initiatives
with government and private- sector entities, including the progress made
regarding the InfraGard Program and development of the key asset database.
In addition, GAO was asked to determine the purposes for which

the NIPC used funding provided for fiscal years 1999 and 2000. Background
Since the early 1990s, an explosion in computer interconnectivity, most

notably growth in the use of the Internet, has revolutionized the way that
the government, the nation, and much of the world communicate and conduct
business. The benefits have been enormous in terms of faster communications
and easier access to data. However, this widespread interconnectivity
carries enormous risks to computer systems and, more importantly, to the
critical operations and infrastructures they support, such as
telecommunications, power distribution, national defense, and essential
government services.

Malicious attacks, in particular, are a growing concern. The National
Security Agency has determined that foreign governments already have or are
developing computer attack capabilities, and that potential adversaries

are developing a body of knowledge about U. S. systems and methods to attack
them. In addition, reported incidents have increased dramatically in recent
years. As a result, a clear risk exists that terrorists or hostile foreign

states could launch computer- based attacks on systems supporting critical
infrastructures to severely damage or disrupt national defense or vital
public operations or steal sensitive data.

Concerns about computer- based vulnerabilities have been reported repeatedly
during the 1990s. Since 1997- most recently in January 2001- GAO, in reports
to the Congress, 1 has designated information security as a governmentwide
high- risk area. In addition, in its October 1997 report, 2 the President?s
Commission on Critical Infrastructure Protection described, from a national
perspective, the potentially devastating implications of

poor information security. The report stated that a comprehensive effort
would need to ?include a system of surveillance, assessment, early warning,
and response mechanisms to mitigate the potential for cyber threats.? It
said that the Federal Bureau of Investigation (FBI) had already begun to
develop warning and threat analysis capabilities and urged it to continue in
these efforts. In addition, the report noted that the FBI could

serve as the preliminary national warning center for infrastructure attacks
and provide law enforcement, intelligence, and other information needed to
ensure the highest quality analysis possible. In May 1998, PDD 63 was issued
in response to the commission?s report. The directive called for a range of
actions intended to improve federal agency security programs, establish a
partnership between the government and the private sector, and improve the
nation?s ability to detect and respond to serious computer- based attacks.
The directive established a National Coordinator for Security,
Infrastructure Protection, and CounterTerrorism under the Assistant to the
President for National Security Affairs. Further, the directive designated
lead agencies to work with private- sector entities in each of eight
industry sectors and five special functions. For example, the Department of
the Treasury was responsible for working with the banking and finance
sector, and the Department of Energy was

responsible for working with the electric power industry. PDD 63 also
authorized the FBI to expand the NIPC, which had been originally established
in February 1998. The directive specifically assigned the NIPC

responsibility for providing comprehensive analyses on threats,
vulnerabilities, and attacks; issuing timely warnings on threats and
attacks; facilitating and coordinating the government?s response to cyber
incidents; providing law enforcement investigation and response; monitoring

1 High- Risk Series: Information Management and Technology (GAO/ HR- 97- 9,
February 1, 1997); High- Risk Series: An Update (GAO/ HR- 99- 1, January,
1999); High- Risk Series: An Update (GAO- 01- 263, January 2001). 2 Critical
Foundations: Protecting America's Infrastructures, the Report of the
President's Commission on Critical Infrastructure Protection, October 1997.

reconstitution of minimum required capabilities after an infrastructure
attack; and promoting outreach and information sharing.

Results in Brief The NIPC has initiated a variety of critical infrastructure
protection efforts that, together, have laid a foundation for future
governmentwide efforts. However, the analytical and information- sharing
capabilities that PDD 63 asserts are needed to protect the nation?s critical
infrastructures have not

yet been achieved. The NIPC has issued numerous analyses to support
investigations of individual incidents, but it has developed only limited
capabilities for strategic analysis of threat and vulnerability data.
Accordingly, the NIPC often is not able to provide timely information on
changes in threat conditions or warnings of imminent attacks. Developing
such capabilities is a formidable task, and experts say it will take an
intense

interagency effort to develop the related methodology. In addition,
information on critical infrastructure components has not been provided to
the NIPC, and the NIPC does not yet have adequate staff and technical
expertise. A major underlying problem is that the NIPC?s roles and

responsibilities have not been fully defined and are not consistently
interpreted by other entities involved in the government?s broader critical
infrastructure protection strategy. Further, these entities have not
provided the information and support, including staff detailees, to the NIPC
that were envisioned by PDD 63 and that are needed to support development of
analysis and warning capabilities. The NIPC has had greater success in
providing technical support and

coordination for the FBI?s investigations of attacks on computer systems,
which it refers to as ?computer crime.? In particular, the NIPC has provided
valuable tools and technical assistance to the squads and teams

that the FBI has established in its field offices to investigate the growing
number of attacks on computer systems. In addition, it has developed
procedures for establishing crisis management teams to respond to
potentially serious computer- based incidents. Since 1998, seven such teams
have been established to address incidents such as the Melissa virus in
1999, the transition to the year 2000, and denial- of- service attacks in
February and March 2000.

Progress in establishing information- sharing partnerships between the NIPC
and private- sector and government entities has been mixed. NIPC?s InfraGard
Program for sharing information on computer- based threats and

incidents with individual companies and organizations has enrolled over 500
members. However, of four information- sharing and analysis centers
established as focal points for infrastructure sectors, only one- the
electric

power industry- had developed a two- way, information- sharing partnership
with the NIPC at the close of GAO?s review. Further, fully productive
partnerships have not been established with other federal entities, most
notably the Department of Defense and the Secret Service, which also collect
and analyze data on computer- based threats and

vulnerabilities. In accordance with congressional direction, the NIPC
obligated about $24 million and about $27 million for fiscal years 1999 and
2000, respectively, according to GAO?s analysis of data provided by the FBI
and the NIPC. The NIPC reportedly used about 84 percent of these amounts to
develop analysis and warning, investigative support, and outreach and
informationsharing capabilities at the NIPC?s Washington, D. C., office. The
remainder of the funds was used to support computer crime investigations
conducted at FBI field offices.

GAO is making a variety of recommendations to the Assistant to the President
for National Security Affairs and the Attorney General regarding the need to
more fully define the role and responsibilities of the NIPC, develop plans
for establishing analysis and warning capabilities, and

formalize information- sharing relationships with private- sector and
federal entities. Principal Findings Multiple Factors Have PDD 63 assigns
the NIPC responsibility for developing analytical Limited Progress in
capabilities to provide comprehensive information on changes in threat
DevelopingAnalysis and

conditions and newly identified system vulnerabilities as well as timely
Warning Capabilities warnings of potential and actual attacks. This
responsibility requires obtaining and analyzing intelligence, law
enforcement, and other

information to identify patterns that may signal that an attack is underway
or imminent. Since its establishment in 1998, the NIPC has issued a variety
of analytical products, including 15 situation reports for law enforcement
investigations and a variety of publications. Most of these have been
tactical analyses

pertaining to individual incidents. Strategic analysis to determine the
potential broader implications of individual incidents has been limited.
Such analysis would assist in evaluating the risks associated with possible
future incidents and allow for effective mitigating actions and proactive
risk management.

Three factors have hindered the NIPC?s ability to develop strategic
analytical capabilities. First, there is no generally accepted methodology
for analyzing strategic cyber- based threats. For example, there is no
standard terminology, no standard set of factors to consider, and no

established thresholds for determining the sophistication of attack
techniques. According to officials in the intelligence and national security
community, developing such a methodology would require an intense
interagency effort and dedication of resources. Second, the NIPC has

sustained prolonged leadership vacancies and does not have adequate staff
expertise. For example, the Chief of the Analysis and Warning Section
position, which was to be filled by the Central Intelligence Agency, was
vacant for about half of the NIPC?s 3- year existence. In addition, the NIPC
has been operating with only 13 of the 24 analysts that NIPC officials
estimate are needed to develop analytical capabilities. Third, the NIPC does
not have industry- specific data on factors such as critical system
components, known vulnerabilities, and interdependencies. Under PDD 63, such
information is to be developed for each of eight industry segments by
industry representatives and the designated federal lead agencies. However,
at the close of GAO?s work, only three industry assessments had

been partially completed, and none had been provided to the NIPC. To provide
a warning capability, the NIPC established a Watch and Warning Unit that
monitors the Internet and other media 24 hours a day to identify reports of
computer- based attacks. Since 1998, the unit has issued 81 warnings and
related products, many of which were posted on the NIPC?s Internet Web site.
While some warnings were issued in time to avert damage, most of the
warnings, especially those related to viruses,

pertained to attacks underway. The NIPC?s ability to issue warnings promptly
is impeded because of (1) a lack of a comprehensive governmentwide or
nationwide framework for promptly obtaining and analyzing information on
imminent attacks, (2) a shortage of skilled staff, (3) the need to ensure
that the NIPC does not raise undue alarm for insignificant incidents, and
(4) the need to ensure that sensitive information is protected, especially
when such information pertains to law enforcement investigations underway.

Evaluating the NIPC?s progress in developing analysis and warning
capabilities is difficult because the federal government?s strategy and
related plans for protecting the nation?s critical infrastructures from
computer- based attacks, including the NIPC?s role, are still evolving. As a

result,  the entities involved in the government?s critical infrastructure
protection efforts do not share a common interpretation of the NIPC?s roles
and responsibilities;

 the relationships between the NIPC, the FBI, and the National Coordinator
for Security, Infrastructure Protection, and CounterTerrorism at the
National Security Council are unclear regarding who has direct authority for
setting NIPC priorities and procedures and providing NIPC oversight;  the
NIPC?s role has not been formally recognized as part of national

security warning procedures, which provide a means of alerting the most
senior federal officials, including the President, of serious or imminent
threats to national security; and  the NIPC and the defense and
intelligence communities have not

developed (1) criteria for determining when a computer- based attack should
be treated as a national security event, rather than as a crime, and (2)
protocols for placing the NIPC in a support role, rather than a lead role,
should such a national security event occur.

An additional impediment to evaluating the NIPC?s progress is that the
NIPC?s plans for further developing its analytical and warning capabilities
are fragmented and incomplete. As a result, there are no specific
priorities, milestones, or program performance measures to guide NIPC
actions or to provide a basis for evaluating its progress.

At the close of GAO?s review, in February 2001, the National Coordinator
said that the administration had begun to consider options for adjusting the
federal strategy for critical infrastructure protection originally outlined
in PDD 63, including provisions related to the development of analytical and

warning capabilities currently assigned to the NIPC. He said that one intent
of any such adjustments would be to clarify roles and responsibilities in
this area. On the basis of the criteria provided in PDD 63 and related
plans, GAO recommends that the Assistant to the President for National
Security Affairs, in coordination with pertinent executive agencies,

 establish a capability for strategic analysis of computer- based threats,
including developing related methodology, acquiring staff expertise, and
obtaining infrastructure data;  require development of a comprehensive data
collection and analysis framework and ensure that national watch and warning
operations for

computer- based attacks are supported by sufficient staff and resources; and
 clearly define the role of the NIPC in relation to other government and

private- sector entities. In addition, GAO recommends that the Attorney
General task the FBI Director to require the NIPC Director to develop a
comprehensive written plan for establishing analysis and warning
capabilities.

The NIPC Has Provided The NIPC has provided coordination and technical
support to FBI field

Valuable Investigation and offices, which have established special squads
and teams and one regional Response Support

task force to address the growing number of computer crime cases. As of
December 31, 2000, the FBI had established such squads, each consisting of
approximately 8 FBI agents, in 16 of the FBI?s 56 field offices. In
addition, 40 smaller teams of from 1 to 5 agents, dedicated to working
computer crime cases, had been established in the remaining FBI field
offices. The

number of agents assigned to NIPC squads and teams increased from 76 agents
in 1998 to approximately 200 agents for fiscal years 1999 and 2000. While
the NIPC provides support, the NIPC squads are under the field offices?
direct supervision. Accordingly, the field offices determine when a case is
to be opened and whether an incident needs to be referred to other federal,
state, or local law enforcement entities. Generally, the NIPC becomes
involved when notified by the field squads through case- initiation

paperwork or requests for technical assistance. The NIPC has coordinated and
supported computer crime investigations by (1) coordinating investigations
among FBI field offices, thereby bringing a national perspective to
individual cases; (2) providing technical support in the form of analyses,
expert assistance for interviews, and tools for

analyzing and mitigating computer- based attacks; and (3) providing
administrative support to NIPC field agents. For example, the NIPC produced
over 250 written technical reports during 1999 and 2000, developed
analytical tools to assist in investigating and mitigating

computer- based attacks, and managed the procurement and installation of
hardware and software tools for each of the NIPC field squads and teams.

While these efforts have benefited the FBI?s investigation efforts,
insufficient computer capacity and data transmission capabilities are
limiting the NIPC?s ability to perform technical analyses promptly. In
addition, FBI field offices are not yet providing the NIPC with the
comprehensive information that officials say is needed to facilitate prompt
identification and response to cyber incidents. The NIPC has developed
budget requirements and performance measures to address these problems.

The NIPC also has developed crisis management capabilities to support a
multiagency response to the most serious incidents from the FBI?s
Washington, D. C., Strategic Information Operations Center. Since 1998,

seven crisis action teams have been activated to address potentially serious
incidents and events, such as the Melissa virus in 1999 and the days
surrounding the transition to the year 2000, and related procedures have
been formalized. In addition, the NIPC has developed a draft emergency

law enforcement plan to guide the response of federal, state, and local
entities. As of mid- February 2001, the draft plan was being reviewed by law
enforcement sector members. PDD 63 also requires the NIPC to develop
capabilities to ?monitor reconstitution? of minimum required capabilities
after an infrastructure attack. However, NIPC officials told GAO that they
have not planned or

taken any action in this regard because specific expectations for meeting
the requirements briefly mentioned in PDD 63 and the National Plan for
Information Systems Protection have not been further defined. As a result,

while the NIPC has established procedures for crisis management teams,
previously discussed, it is not clear what responsibilities these teams
would have regarding any reconstitution efforts that may be needed as the
result of a seriously damaging attack.

The National Coordinator agreed that the NIPC?s specific role in this area
was not clear and said that this issue would probably be addressed as the
administration reviews the government?s critical infrastructure protection
strategy and the specific requirements for the NIPC.

GAO recommends that the Attorney General direct the FBI Director to direct
the NIPC Director to (1) ensure that the NIPC has access to needed computer
and communications resources, (2) monitor implementation of new performance
measures to ensure that FBI field offices fully report information on
potential computer crimes to the NIPC, and (3) complete development of the
emergency law enforcement plan. In addition, GAO

recommends that the Assistant to the President for National Security Affairs
define the NIPC?s responsibilities for monitoring reconstitution. Mixed
Progress in Information sharing and coordination among private- sector and
Establishing InformationSharing government organizations are essential to
thoroughly understanding cyber Relationships

threats and quickly identifying and mitigating attacks. However, as GAO
testified in July 2000, 3 establishing the trusted relationships and
information- sharing protocols necessary to support such coordination can be
difficult.

NIPC efforts to establish information- sharing relationships with private
organizations have met with mixed success, as shown in the following
examples:

 A two- way, information- sharing partnership has developed with only one-
the electric power industry- of the four information- sharing and analysis
centers that have been established as focal points for infrastructure
sectors. The NIPC?s dealings with two of the other three centers have
primarily consisted of providing information without

receiving any in return, and no procedures have been developed for more
interactive information sharing. GAO cannot comment on the NIPC?s
information- sharing relationship with the fourth center because it was not
established until mid- January 2001, just before the close of GAO?s review.
 Expansion of the InfraGard Program, which provides the FBI and the

NIPC with a means of securely sharing information with individual companies,
has been more successful. In January 2001, NIPC officials announced that 518
organizations had enrolled in the program. GAO did not survey InfraGard
members and, therefore, cannot comment on their satisfaction with the
program. However, NIPC officials view InfraGard

as an important step in building trust relationships with the private
sector.  The NIPC and the FBI have made only limited progress in developing
a database of the most important components of the nation?s critical
infrastructures, referred to as the Key Asset Initiative. While FBI field
offices have identified over 5,000 key assets, they had not yet been

successful in obtaining the agreement of the industry sectors 3 Critical
Infrastructure Protection: Challenges to Building a Comprehensive Strategy
for Information Sharing and Cooperation (GAO/ T- AIMD- 00- 268, July 26,
2000).

responsible for these assets. In addition, the Key Asset Initiative is not
being coordinated with other similar federal efforts at the Departments of
Defense and Commerce. Further, the NIPC and other government entities have
not established fully productive information- sharing and cooperative
relationships. Federal agencies have not routinely reported incident
information to the NIPC, at

least in part because guidance provided by the federal Chief Information
Officers Council, which is chaired by the Office of Management and Budget?s
Deputy Director for Management, directs agencies to report such information
to the General Services Administration?s Federal Computer Incident Response
Capability. NIPC and Defense officials agree that their

information- sharing procedures need improvement, noting that protocols for
reciprocal exchanges of information have not been established. In addition,
the expertise of the Secret Service regarding computer crime has not been
integrated into NIPC efforts.

The NIPC has been more successful in providing training on investigating
computer crime to government entities, which is an effort that it considers
an important component of its outreach efforts. From 1998 through 2000, the
NIPC trained about 300 individuals from federal, state, local, and
international entities other than the FBI. In addition, the NIPC has advised
five foreign governments that are establishing centers similar to the NIPC.

GAO recommends that the Assistant to the President for National Security
Affairs (1) direct federal agencies and encourage the private sector to
better define the types of information necessary and appropriate to exchange
in order to combat computer- based attacks and to develop procedures for
performing such exchanges, (2) initiate development of a strategy for
identifying assets of national significance that includes coordinating
efforts already underway, and (3) resolve discrepancies in requirements
regarding computer incident reporting by federal agencies.

GAO further recommends that the Attorney General task the FBI Director to
(1) formalize information- sharing relationships between the NIPC and other
federal entities and industry sectors and (2) ensure that the Key Asset
Initiative is integrated with other similar federal activities.

Funding Used for a Variety In accordance with congressional direction, the
FBI reportedly designated of NIPC- related Activities about $32 million in
fiscal year 1999 and about $28 million in fiscal year 2000 for the NIPC. In
addition, the FBI provided the NIPC with

administrative services, including budgeting, accounting, training,
telecommunications, and facilities, at no cost to the NIPC. Other government
agencies provided the NIPC with additional resources in the form of at least
39 detailees during fiscal years 1999 and 2000, who filled a variety of NIPC
positions on a nonreimbursable basis. On the basis of GAO?s analysis of
information provided to it by the FBI and the NIPC, the

NIPC obligated about 84 percent of its available fiscal years 1999 and 2000
funds. The rest of the available funds that the NIPC did not obligate were
?no- year? funds that remained available for fiscal year 2001. The NIPC
reportedly used most of its fiscal years 1999 and 2000 funds for activities
performed by its staff in Washington, D. C. These included analysis and
warning activities, investigation of cyber incidents, and outreach and
information sharing with government and private- sector entities. The NIPC
used the remainder of its funds- about 16 percent- to pay for training,
travel, and information technology for NIPC field squads

and teams located in FBI field offices. These funds supplemented the funding
for NIPC field squads? salaries and expenses that was provided by the FBI.
GAO reviewed the funding information the NIPC provided for consistency;
however, it did not independently verify the data on obligations or review
the NIPC?s related internal- control procedures.

Agency Comments and In comments on a draft of this report, the Director of
the NIPC generally

Our Evaluation agreed with GAO?s findings and stated that the NIPC considers
it of the

utmost urgency to address the shortcomings identified. The Director
expressed the view that it is most important that the NIPC receive adequate
staffing, particularly from the defense and intelligence communities, in
order to address the lack of strategic analysis. The Director also noted the
challenges associated with establishing information- sharing relationships
with other organizations. Specifically, he stated that the Department of
Justice and the NIPC have worked, and will continue to work, to develop
effective protocols for information sharing within the bounds of each
component?s legal and policy structures and provide a level of certainty
that shared information will be appropriately protected. He asserted that,
through such protocols, information necessary for protecting infrastructures
can be effectively shared on a timely basis. In addition, the Director
emphasized that the NIPC had been in existence for only 3 years

and that its performance should be measured in the context of its recent
formation. Finally, the Director noted that GAO?s draft report did not
recommend a change to the basic PDD 63 framework. In this regard, he
expressed the view that the FBI is the only locus where law enforcement,

counterintelligence, foreign intelligence, and private- sector information
may be lawfully and collectively analyzed and disseminated, all under
welldeveloped statutory protections and oversight of Justice.

The Director?s letter did not comment on GAO?s recommendations to the NIPC
regarding the need to (1) develop a comprehensive integrated plan for
developing analysis and warning capabilities, (2) ensure that the Special
Technologies and Applications Unit has access to adequate computer and

communications resources, (3) monitor implementation of new performance
measures regarding field office reporting of information on potential
computer crimes, (4) formalize relationships with other federal entities,
and (5) ensure that the Key Asset Initiative is integrated with other

similar federal activities. The NIPC?s comments reiterate many of the points
made in GAO?s report regarding the NIPC?s accomplishments related to
developing analysis and warning, investigative, and information- sharing
capabilities. However, the NIPC did not comment on several key
recommendations, including the need to improve cooperative relationships
with other federal entities, such as Defense and the Secret Service.
Establishing such cooperation is essential if the NIPC is to effectively
serve as the government?s focal point for analysis and warning regarding
cyber threats. Also, as the NIPC Director states, GAO did not recommend a
change to the basic PDD 63

framework, including changing the placement of the NIPC. GAO did not make
such a recommendation because moving the NIPC from the FBI to another agency
or establishing it as a stand- alone entity would not necessarily ensure
that the deficiencies GAO identified would be addressed. These deficiencies,
which included lack of a generally accepted

methodology for strategic analysis, lack of data on infrastructure
vulnerabilities and incidents, and insufficient staff resources, are
problems that need to be addressed regardless of the NIPC?s organizational

placement. In comments on a draft of this report, the Special Assistant to
the President and Senior Director for Legislative Affairs at the National
Security Council said that the report highlighted the need for a review of
the roles and

responsibilities of the federal agencies involved in U. S. critical
infrastructure protection support. The comments stated that our
recommendations would be considered as the administration reviews federal
cyber activities to determine how the critical infrastructure protection
function should be organized. Regarding further development of analysis and
warning capabilities, the Special Assistant to the President

noted that some functions might be better accomplished by distributing the
tasks across several existing federal agencies, creating a ?virtual analysis
center? that would provide not only a governmentwide analysis and

reporting capability, but that could also support rapid dissemination of
cyber threat and warning information. The comments did not specifically
address GAO?s recommendations to the Assistant to the President for National
Security Affairs regarding (1) defining the NIPC?s responsibilities

for monitoring reconstitution, (2) better defining needed information for
combating cyber attacks, (3) developing a strategy for identifying assets of
national significance, and (4) resolving discrepancies in guidance on
computer incident reporting by federal agencies. Comments from the NIPC and
the National Security Council are printed in full in appendixes I and II,
respectively.

Chapt er 1

Introduction Since the early 1990s, an explosion in computer
interconnectivity, most notably growth in the use of the Internet, has
revolutionized the way that our government, nation, and much of the world
communicate and conduct business. The benefits have been enormous. Vast
amounts of information are now literally at our fingertips, facilitating
research and government services. Financial and other business transactions
can be executed almost instantaneously, and electronic mail, Internet Web
sites, and computer bulletin boards allow us to communicate quickly and
easily with virtually an unlimited number of other individuals and groups.
However, this widespread interconnectivity also poses enormous risks to our
computer systems and, more importantly, to the critical operations and

infrastructures they support, such as telecommunications, power
distribution, national defense, and critical government services. To reduce
these risks, in 1998, the President issued Presidential Decision Directive
63 (PDD 63), which describes a strategy for cooperative efforts by
government and the private sector to protect critical, computerdependent
operations. A key element of this strategy is the establishment of the
National Infrastructure Protection Center (NIPC) as ?a national focal

point? for gathering information on threats and providing the principal
means of facilitating the federal government?s response to computer- based
incidents. To determine how effectively the NIPC is addressing current and
future cyber threats to our national security, the Subcommittee on
Technology, Terrorism, and Government Information, Senate Committee on the
Judiciary, asked that we examine the NIPC?s progress in developing national
capabilities for analyzing data about, issuing warnings on, and

responding to computer- based attacks. In addition, the Subcommittee asked
that we determine the purposes for which the NIPC used funding provided for
fiscal years 1999 and 2000. Cyber Risks to Critical

The risks associated with our nation?s reliance on interconnected computer
Infrastructures Are

systems are substantial and varied. Attacks can come from anywhere in the
world, over the Internet, other networks, and dial- up lines. By Substantial
and

launching attacks across a span of communications systems and Increasing

computers, attackers can effectively disguise their identity, location, and
intent, thereby making them difficult and time- consuming to trace.

Such attacks could severely disrupt computer- supported operations,
compromise the confidentiality of sensitive information, and diminish the
integrity of critical data. A significant concern is that terrorists or
hostile foreign states could launch computer- based attacks on critical
systems to severely damage or disrupt national defense or other critical
operations or steal sensitive data, resulting in harm to the public welfare.
According to the National Security Agency, foreign governments already have
or are developing computer attack capabilities, and potential adversaries
are developing a body of knowledge about U. S. systems and about methods to
attack these systems. Figure 1 provides an overview of the various types of
risks.

Figure 1: Risks to Computer- Based Operations

While cyber- based attacks have not yet caused devastating disruptions, the
number of attacks is increasing. Complete summary data are not available
because many incidents are not reported. However, the number of

reported incidents handled by Carnegie- Mellon University?s CERT
Coordination Center 1 has increased from about 1,300 in 1993 to about 9,800
in 1999 and to over 21, 000 in 2000. Similarly, the Federal Bureau of
Investigation (FBI) reports that its caseload of computer intrusion- related

investigations more than doubled from 1998 to 2000. This greater number of
attacks increases the risk of incidents with devastating consequences.
According to the FBI, the following threats have been observed: Criminal
groups. There is an increased use of cyber intrusions by criminal groups who
attack systems for purposes of monetary gain.

Foreign intelligence services. Foreign intelligence services use cyber tools
as part of their information gathering and espionage activities.

Hackers. Hackers sometimes crack into networks for the thrill of the
challenge or for bragging rights in the hacker community. While remote
cracking once required a fair amount of skill or computer knowledge, hackers
can now download attack scripts and protocols from the Internet and launch
them against victim sites. Thus, while attack tools have become

more sophisticated, they have also become easier to use. Hacktivists.
Hacktivism refers to politically motivated attacks on publicly accessible
Web pages or e- mail servers. These groups and individuals overload e- mail
servers and hack into Web sites to send a political message. 1 Originally
called the Computer Emergency Response Team, the CERT Coordination Center
was established in 1988 by the Defense Advanced Research Projects Agency.
The center is charged with (1) establishing a capability to quickly and
effectively coordinate communication among experts in order to limit the
damage associated with, and respond to, incidents and (2) building awareness
of security issues across the Internet community.

Information warfare. Several nations are aggressively working to develop
information warfare doctrine, programs, and capabilities. Such capabilities
enable a single entity to have a significant and serious impact by
disrupting

the supply, communications, and economic infrastructures that support
military power- impacts that, according to the Director of Central
Intelligence, 2 can affect the daily lives of Americans across the country.

Insider threat. The disgruntled organization insider is a principal source
of computer crimes. Insiders may not need a great deal of knowledge about
computer intrusions because their knowledge of victim systems often allows
them to gain unrestricted access to cause damage to the system or to steal
system data. Virus writers. Virus writers are posing an increasingly serious
threat.

Several destructive computer viruses and ?worms? have harmed files and hard
drives, including the Melissa Macro Virus, the Explore. Zip worm, and the
CIH (Chernobyl) Virus.

Concern About Critical Concerns about computer- based vulnerabilities have
been publicly Infrastructure reported repeatedly during the 1990s. Examples
of these concerns include

the following: Protection Has Been Growing

 In 1991, the National Research Council studied the issue and reported that
?as computer systems become more prevalent, sophisticated, embedded in
physical processes and interconnected, society becomes more vulnerable to
poor system design, accidents that disable systems, and attacks on computer
systems.? 3 The report generated a great deal of interest in both the
government and private sectors, alerting them to vulnerabilities and dangers
being rapidly introduced with technology

dependence.  In June 1995, a Critical Infrastructure Working Group, led by
the Attorney General, was formed to (1) identify critical infrastructures
and assess the scope and nature of threats to them, (2) survey existing
government mechanisms for addressing these threats, and (3) propose 2
Prepared Statement of George J. Tenet, Director of Central Intelligence,
before the Senate

Select Committee on Intelligence, February 2, 2000. 3 Computers at Risk:
Safe Computing in the Information Age, the National Research Council, 1991.

options for a full- time group to consider long- term government response to
threats to critical infrastructures. The working group identified critical
infrastructures, characterized threats to them, and

recommended creating a commission to investigate such issues.  In February
1996, the National Defense Authorization Act required the

executive branch to provide a report to the Congress on the policies and
plans for developing capabilities, such as warnings of strategic attacks
against the national information infrastructure. 4 Later that year, the
Permanent Subcommittee on Investigations, Senate Committee on Governmental
Affairs, began to hold hearings on security in cyberspace. Since then,
congressional interest in protecting national infrastructures has remained
strong.  In July 1996, the President?s Commission on Critical
Infrastructure Protection was established to investigate the nation?s
vulnerability to both cyber and physical threats.  Since 1997- most
recently in January 2001- we have designated

information security as a governmentwide high- risk area, in reports to the
Congress. 5  In October 1997, the President?s Commission issued its report,
6 which

described the potentially devastating implications of poor information
security from a national perspective. The report stated that a comprehensive
effort would need to ?include a system of surveillance, assessment, early
warning, and response mechanisms to mitigate the potential for cyber
threats.? It said that the FBI had already begun to develop warning and
threat analysis capabilities and urged it to continue

in these efforts. In addition, the report noted that the FBI could serve as
the preliminary national warning center for infrastructure attacks and
provide law enforcement, intelligence, and other information needed to
ensure the highest quality analysis possible.

4 National Defense Authorization Act of Fiscal Year 1996 , P. L. 104- 106,
Div. A, Title X, Subtitle E, Section 1053. 5 High- Risk Series: Information
Management and Technology (GAO/ HR- 97- 9, February 1, 1997); High- Risk
Series: An Update (GAO/ HR- 99- 1, January 1999); and High- Risk Series: An
Update (GAO- 01- 263, January 2001).

6 Critical Foundations: Protecting America?s Infrastructures, the Report of
the President?s Commission on Critical Infrastructure Protection, October
1997.

PDD 63 Outlined a In response to the commission?s report, the President
initiated actions to National Critical implement a cooperative public-
private approach to protecting the nation?s

critical infrastructures by issuing PDD 63 in May 1998. The directive called
Infrastructure

for a range of activities to improve federal agency security programs,
Protection Strategy establish a partnership between the government and
private sector, and improve the nation?s ability to detect and respond to
serious attacks. The directive established critical infrastructure
protection as a national goal, stating that, by the close of 2000, the
United States was to have achieved an initial operating capability and, no
later than 2003, the capability to protect

the nation?s critical infrastructures from intentional destructive acts. To
accomplish its goals, PDD- 63 designated the National Coordinator for
Security, Infrastructure Protection, and Counter- Terrorism, who reports to
the Assistant to the President for National Security Affairs, to oversee
national policy development and implementation. The directive also
established the National Plan Coordination staff, which became the Critical
Infrastructure Assurance Office, an interagency office that is housed in the
Department of Commerce and is responsible for planning infrastructure
protection efforts. In addition, the directive designated ?lead agencies? to
work with private- sector and government entities in each of eight
infrastructure sectors and five special function areas. For example, the

Department of the Treasury is responsible for working with the banking and
finance sector, and the Department of Energy is responsible for working with
the electric power industry. Similarly, regarding special function areas,
the Department of Defense (DOD) is responsible for national defense, and the
Department of State is responsible for foreign affairs. To facilitate
private- sector participation, PDD 63 encouraged creation of Information
Sharing and Analysis Centers (ISAC) that could serve as mechanisms for
gathering, analyzing, and appropriately sanitizing

and disseminating information to and from infrastructure sectors and the
NIPC. Figure 2 depicts the entities with critical infrastructure protection
responsibilities as outlined by PDD 63.

Figure 2: Critical Infrastructure Protection Responsibilities, as Outlined
by PDD 63

The NIPC Is Assigned The NIPC was originally established by the Attorney
General in February

A Broad Set Of 1998 as an outgrowth of the FBI?s Computer Investigations and

Infrastructure Threat Assessment Center, which is a joint criminal and
Responsibilities intelligence operation focused on computer crimes and
threats to the national information infrastructure. According to the
Attorney General, the NIPC was to become the government?s lead mechanism for
responding to infrastructure attacks.

In May 1998, PDD 63 authorized the FBI to expand the NIPC and directed the
NIPC to gather information on threats and coordinate the federal
government?s response to incidents affecting infrastructures. According to
the NIPC legal counsel, the NIPC was placed in the FBI because of the

bureau?s broad legal authority to collect, retain, and share information
about potential cyber threats to the nation?s critical infrastructures. In
addition, the NIPC benefited from the FBI?s jurisdictional authority and
investigative capability, including conducting and coordinating criminal and
foreign counterintelligence investigations within the United States.

The directive further assigned the NIPC, operating under these authorities,
specific responsibilities for

 issuing timely warnings on threats and attacks;  providing comprehensive
analyses on threats, vulnerabilities, and

attacks;  facilitating and coordinating the government?s response to cyber

incidents;  providing law enforcement investigation and response; 
mitigating cyber attacks;  monitoring reconstitution efforts; and 
promoting outreach and information sharing.

The following documents provide additional detail on the NIPC?s mission and
operational requirements:

 The FBI?s National Infrastructure Protection and Computer Intrusion
Program Plan, issued in April 1999 and updated in October 2000, outlines
specific goals and strategies aimed primarily at developing a national
investigative and response capability, especially as they relate to FBI
field office activities.  The unclassified version of the Attorney
General?s Five- Year Interagency Counterterrorism and Technology Crime Plan,
issued in September 1999, stresses the need for the NIPC to interact with
other federal

counterterrorism and law enforcement efforts and provides specific details
on NIPC programs, objectives, and requirements, such as analysis and warning
operations, crisis management responsibilities, the Key Asset Initiative,
and the InfraGard Program.

 The President?s National Plan for Information Systems Protection, issued
in January 2000, reiterates much of what was contained in the FBI?s April
1999 program plan and the Attorney General?s plan. However, it contained a
broader description of governmentwide efforts and described how other
federal entities might interact with the NIPC.

PDD 63 covered both physical and computer- based threats. However, the
NIPC?s efforts have pertained almost exclusively to computer- based threats,
since this was an area that the leaders of the administration?s critical
infrastructure protection strategy viewed as needing attention. For example,
the FBI 1998 Strategic Plan identified the protection of the

national information infrastructure as one of the Bureau?s highest
priorities. The President?s issuance of the National Plan further
illustrated the administration?s interest in this area. In addition, other
components of the FBI had a lead role in addressing physical threats.
Specifically, the

Attorney General?s 1999 plan noted that in the event of physical attacks on
key infrastructures, the investigative response would be handled by FBI
criminal investigative or counterterrorism components. In such cases, the

NIPC would serve in a supporting role, providing relevant information about
the victim infrastructure and other focused analytical or intelligence
products.

Currently, the NIPC is located in the FBI?s Counterterrorism Division, which
is 1 of 11 FBI headquarters divisions headed by assistant directors who
report to the FBI Director. The NIPC Director reports directly to the
Assistant Director for Counterterrorism.

The NIPC is organized into three sections reflecting the mission areas
identified by PDD 63.  The Computer Investigations and Operations Section
is to support and,

where necessary, coordinate computer investigations conducted by the FBI?s
56 field offices and approximately 400 sublocations throughout the country;
provide expert technical assistance to investigations; and coordinate the
response to a national- level cyber incident.  The Analysis and Warning
Section is to provide tactical analytical support during a cyber incident
and develop strategic analyses of

threats for dissemination to both government and private- sector entities so
that they can take appropriate steps to protect themselves.  The Training,
Outreach, and Strategy Section is to coordinate the

training of investigators in the FBI field offices, other federal agencies,
and state and local law enforcement regarding computer- based threats. It
also is to coordinate outreach activities with private industry and
government agencies to build the partnerships that are key to the NIPC?s
investigative and warning missions. In addition, this section manages

efforts to catalog information about individual "key infrastructure assets"
and manages the InfraGard Program, which provides a forum for private
industry and the NIPC to share information. Figure 3 shows the NIPC?s
organization and identifies subunits in each of its three major functional
sections.

Figure 3: NIPC Organizational Chart

Source: NIPC.

Objectives, Scope, and Our objectives were to evaluate the progress that the
NIPC has made in

Methodology  developing national capabilities regarding cyber threats for
analyzing

threat and vulnerability data and issuing warnings;  enhancing its
capabilities for responding to cyber attacks; and  outreach and sharing
information with government and private- sector entities, including the
progress made regarding the InfraGard Program and development of the key
asset database.

In addition, we were asked to determine the purposes for which the NIPC used
funding provided for fiscal years 1999 and 2000.

To determine the NIPC?s progress in developing capabilities for issuing
warnings and analyzing threat and vulnerability data, we reviewed analytical
reports that the NIPC had issued and held discussions with officials from
the NIPC?s Analysis and Warning Section. We observed a demonstration of the
NIPC?s watch and warning procedures and reviewed

pertinent policies, guidance, and plans. To gain a more thorough
understanding of the challenges associated with analyzing and reporting
computer- based incidents and determine how the NIPC?s responsibilities
relate to those of other federal agencies, we met with officials in the

intelligence community and in DOD who were involved in threat analysis and
warning activities. To determine the NIPC?s progress in enhancing its
capabilities for responding to cyber attacks, we reviewed pertinent
policies, guidance, plans, and other supporting documentation and
interviewed officials in the NIPC?s Computer Investigations and Operations
Section and Analysis and Warning Section. We visited 4 of the FBI?s 56 field
offices, which we selected because they were performing a diverse set of
NIPC- related activities. Three of these field offices- in New Orleans, San
Francisco, and Washington, D. C.- had full NIPC squads. The fourth field
office, in Pittsburgh, had a NIPC team and the only interagency task force
for investigating computer intrusions. During these visits, we observed

operations related to investigating and responding to computer- based
incidents and met with FBI agents involved in these activities.

To determine the NIPC?s progress in outreach and information sharing with
government and private- sector entities, we interviewed officials from the
NIPC?s Training, Outreach, and Strategy Section and from the three
Information Sharing and Analysis Centers (ISAC) that had been established

at the time of our review. (A fourth ISAC for the information technology
industry, announced in January 2001, was not covered by our review.) These
centers pertained to the financial services industry, the

telecommunications industry, and the electric power industry. In addition,
we observed a meeting sponsored by the FBI?s Washington, D. C., field office
to promote participation in the NIPC?s InfraGard information- sharing
program, and a training session on collaborative efforts by the North

American Electric Reliability Council and the NIPC. We also discussed the
InfraGard Program and efforts to develop a database of key infrastructure
assets with responsible officials at the NIPC and four FBI field offices.

Further, we reviewed a variety of documents related to these outreach and
information- sharing efforts.

To gain a more thorough understanding of the adequacy of the NIPC?s progress
regarding our first three objectives, we reviewed various documents that
describe the NIPC?s responsibilities. These included the Attorney General?s
Five- Year Interagency Counterterrorism and Technology Crime Plan and The
National Plan for Information Systems Protection, issued by the President in
January 2000. We also met with federal officials outside of the FBI who were
involved with federal critical infrastructure protection efforts. These
included the National Coordinator and officials from the Office of
Management and Budget (OMB) , the intelligence community, DOD, the Critical
Infrastructure Assurance Office, a former Commissioner from the President?s
Commission on Critical Infrastructure Protection, current and former
detailees to the NIPC from other organizations, and key persons involved in
the creation of PDD 63. In addition, we interviewed the NIPC?s Director,
deputy director, and principal legal counsel. To determine the purposes for
which the NIPC used funding provided for

fiscal years 1999 and 2000, we reviewed pertinent congressional reports,
plans, guidance, and budget documents and reports on obligations developed
for us by FBI and NIPC officials. We also held discussions with FBI finance
division officials and NIPC headquarters officials responsible for funding-
related decisions and for accounting for those funds. We reviewed the
provided information for consistency; however, we did not independently
verify the data on obligations or review the NIPC?s related

internal- control procedures. We performed our audit work from May 2000
through February 2001 in accordance with generally accepted government
auditing standards. We received comments on a draft of this report from the
Director of the NIPC

and the Special Assistant to the President and Senior Director for
Legislative Affairs. The comments are printed in full in appendixes I and
II, respectively.

Multiple Factors Limit Progress in Developing

Chapt er 2

National Analysis and Warning Capabilities The NIPC?s progress in developing
national capabilities for analyzing vulnerability and threat data and
issuing timely warnings of computerbased attacks, as described in PDD 63,
has been limited. However, the NIPC has laid a foundation for further
governmentwide efforts in these areas. Analysis and warning capabilities are
needed to improve the

government?s ability to recognize changes in threat conditions, detect
impending attacks, or effectively warn government and industry of such
attacks in time to prevent serious damage. Since it was established in 1998,
the NIPC has issued a variety of analytical products. Most of these products
have been based on the work of others, with some original NIPC analysis. The
majority of the NIPC?s original analysis has been tactical analysis
performed in support of investigations of individual incidents. Progress in
developing strategic analysis to assess the

broader, long- term implications of such threats has been impeded because
there is no generally accepted methodology for threat analysis, adequate
staff and expertise have not been supplied, and data on infrastructure
vulnerabilities have not been provided by industry sectors. Overcoming these
obstacles will require significant interagency efforts and resources.

The NIPC has developed rudimentary capabilities for issuing warnings. From
February 1998 through December 2000, it issued 81 alerts, advisories, and
assessments. However, most of these warnings pertained to attacks already
underway and, therefore, may have been too late for recipients to take
mitigating action. The NIPC?s efforts to develop a more robust warning
capability have been impeded by a lack of staff expertise and because a
governmentwide or nationwide framework for promptly collecting and analyzing
incident information has not been established. In addition, issuance of
timely warnings has been hindered by the need to

protect sensitive information and verify the accuracy and significance of
reported incidents before issuing related warnings. Further, two fundamental
problems make it difficult to measure the NIPC?s progress and determine its
needs for developing more substantive analysis and warning capabilities.
First, the NIPC?s roles and responsibilities have not been fully defined and
are not consistently interpreted by other federal

agencies responsible for critical infrastructure protection, and these
entities have not provided the NIPC the support envisioned by PDD 63.
Second, the NIPC has not developed a comprehensive and integrated, multiyear
plan of action to prioritize and guide its analysis and warning efforts and
to identify needed resources.

NIPC officials are aware of these problems and have taken some steps to
address them. However, many of these problems cannot be resolved by the NIPC
alone and will require governmentwide efforts. At the close of

our review, the National Coordinator for Security, Infrastructure
Protection, and Counter- Terrorism said that options for adjusting the
federal strategy for critical infrastructure protection were being
considered, including a reassessment of roles and responsibilities
pertaining to the development of analysis and warning capabilities.

PDD 63 Directs the The analysis and warning capabilities called for by PDD
63 presume that NIPC to Develop

analytical processes can be developed to detect precursors to computerbased
attacks so that advance warnings can be issued and protective Analysis and
Warning

measures implemented. Since the 1990s, the national security community
Capabilities and the Congress have identified a need to establish analytical
and warning capabilities, which are sometimes referred to as ?indications
and

warnings,? to protect against strategic computer attacks against the
nation?s critical computer- dependent infrastructures. Such capabilities
involve (1) gathering and analyzing information for the purpose of detecting
and reporting hostile or otherwise potentially damaging actions or
intentions and (2) implementing a process for warning policymakers and

allowing them time to determine the magnitude of the related risks. PDD 63
specifically assigns the NIPC the responsibility for developing analytical
capabilities to provide comprehensive information on changes in threat
conditions and newly identified system vulnerabilities and timely warnings
of actual or potential attacks. According to the Attorney

General?s Five- Year Interagency Counterterrorism and Technology Crime Plan,
issued in 1999, the NIPC?s functions are to include analyzing risks to
infrastructures, understanding the indicators of a computer- based attack,
establishing the technical capability to identify indicators, and
determining what constitutes an attack by a foreign power. The January 2000
National

Plan for Information Systems Protection further specifies that the NIPC will
combine the information it obtains on computer- based attacks with
intelligence, law enforcement, and other indicator information to identify
patterns that may signal that an attack is underway or imminent.

Analyses Have To develop the analytical capabilities specified in PDD 63 and
related

Primarily Supported requirements, the NIPC created the Analysis and
Information Sharing Unit (AISU) in May 1998. According to the National
Infrastructure Protection Investigations of

and Computer Intrusion Program Plan, the AISU is to provide both (1)
Individual Incidents tactical analytical support during a cyber incident and
(2) strategic

analyses of threats. Tactical support involves providing current information
on specific factors associated with incidents under investigation or
specific identified vulnerabilities. Examples of tactical support include
analysis of (1) a computer virus delivery mechanism to

issue immediate guidance on ways to prevent or mitigate damage related to an
imminent threat or (2) a specific computer intrusion or set of intrusions to
determine the perpetrator, motive, and method of attack. In contrast,
strategic analysis looks beyond one specific incident to consider a broader
set of incidents or implications that may indicate a potential threat of
national importance. For example, strategic analyses

may identify long- term vulnerability and threat trends that provide advance
warnings of increased risk, such as emerging attack methods. Strategic
analyses are intended to provide policymakers with information that they can
use to anticipate and prepare for attacks, thereby diminishing such attacks?
damage.

Analyses Have Primarily Since its establishment, most of the AISU?s
activities have been focused on Addressed Tactical Issues tactical analyses
related to investigations of individual cyber incidents or notices of
recently reported vulnerabilities. As of early November 2000, the

AISU had produced 15 tactical situation reports related to law enforcement
investigations. Twelve of these situation reports were associated with
investigations of denial- of- service attacks that affected numerous
Internet

entities, including E- Bay and Yahoo, in February 2000. In addition to
efforts resulting in written products, the AISU has assisted in
investigations of other incidents that were quickly resolved and did not
result in formal reports. For example, in July 2000, AISU analysts spent
several days

supporting efforts to monitor an incident associated with a classified
system that did not evolve into a significant incident and, therefore, did
not result in a written report. In addition, since 1998, the AISU has
provided analytical support related to a counterintelligence investigation,
which involves a complicated series of computer intrusions into federal
agencies, universities, and private- sector systems. As of December 2000,
this effort had resulted in 12 analytical

documents, which, unlike most of the AISU?s other efforts, included both
tactical and strategic analyses. NIPC officials say that these analyses have
provided valuable experience that the AISU is using to develop improved
methods for identifying perpetrators and understanding their actions. For
example, the NIPC initiated Project La Resistance, which is a strategic
effort to analyze information gathered from disparate sources, including law
enforcement and intelligence agencies, private industry, and other open
sources, to identify linkages and commonalties among incidents and

perpetrators. The AISU has also issued a variety of publications, most of
which were compilations of information previously reported by others with
some NIPC analysis. Its most widely disseminated documents include a
biweekly publication called CyberNotes, a compilation of reports by other
sources on software vulnerabilities, hacker techniques, and virus
information, which is intended for use by security professionals. CyberNotes
is presented in a summary table format that includes pertinent information
on

each vulnerability, such as vendor and operating system, software name,
potential impact, remedies, and an indication of whether any attacks have
actually exploited the vulnerability or attack technique. The NIPC also
produces and broadly distributes the Daily Watch, a listing of daily
developments affecting infrastructures, which is compiled from a range of
sources. In January 2001, the NIPC introduced Highlights (formerly known

as Critical Infrastructure Developments) as a publication intended to
provide information on infrastructure protection issues, with a specific
emphasis on computer and network security matters.

Limited Strategic Analysis While the NIPC has provided support to the
previously mentioned

Performed counterintelligence investigation and input into two intelligence

community documents, including the recent National Intelligence Estimate on
cyber threats, overall, it has performed limited strategic analysis. As a
result, information on individual incidents or groups of incidents has not
been fully taken advantage of to assist in identifying broader, longer- term
risks. For example, in October 1999, the NIPC issued an advisory on a
Trojan- horse program dubbed ?RingZero,? describing it as an ?aggressive
reconnaissance technique? used to obtain detailed information on systems
that could be used to facilitate future attacks. 1 The NIPC advisory was

1 NIPC Advisory 99- 024: RingZero Trojan Program Issued at 3: 00 p. m., EDT,
October 22, 1999.

based on analyses obtained from the Systems Administration, Networking, and
Security (SANS) Institute, which is a cooperative research and education
organization, and the Naval Surface Warfare Center. These analyses
highlighted the possible malicious uses of RingZero for anonymously
performing large distributed attacks. However, the NIPC made no attempt to
determine the potential strategic implications of RingZero and more
thoroughly understand the related risks to national infrastructures.
Additional analysis was not performed because, according

to the Chief of the AISU, staff were diverted to other incidents of more
immediate concern. NIPC officials told us that the RingZero analysis was an
example of how their efforts to develop strategic analysis capabilities had
been limited because the AISU?s analysts were fully engaged in supporting a
growing stream of new and ongoing investigations of computer- based
incidents. This point was corroborated in an October 2000 National
Infrastructure Protection and Computer Intrusion Program Plan, issued by the
FBI?s Counterterrorism Division, which stated that, while over 1, 000
computer crime investigations were underway, the NIPC could only provide
regular

analytical support to fewer than a dozen of the most important cases.
Impediments to Developing The experts we interviewed at the NIPC and other
federal agencies agreed More Substantive Analytical

that developing substantive capabilities for analyzing computer- based
Capabilities

threats is a formidable task, especially in the area of strategic analysis.
No generally accepted methodology in this area exists, and analytical
expertise and reliable data on infrastructure vulnerabilities are in short
supply. These factors have impeded the NIPC?s progress in this area.

Lack of Methodology for According to federal intelligence and national
security officials, no Strategic Analysis

generally accepted methodology for strategic analysis of cyber threats to
the nation?s infrastructures has been developed. Lacking are a standard
terminology, a standard set of factors to consider, and established
thresholds for determining the sophistication of attack techniques. As a
result, no proven or generally accepted approach exists that the NIPC can
readily adopt to perform such analyses. The intelligence community officials
we met with said that developing such a methodology would require an intense
interagency effort and a dedication of significant resources.

Lack of Needed Staff and According to senior NIPC officials, the AISU has
depended to a large extent Expertise on detailees from other agencies to
supplement FBI staff. Although the FBI has investigative capabilities, it
acknowledges that it lacks staff who are experienced in critical
infrastructure operations and intelligence analysis. The NIPC Director told
us that the use of detailees was intended to be a

means of rapidly assembling an analytical capability from existing expertise
within the federal government and that, in his view, it was important for
the NIPC to draw on the expertise and diverse perspectives of personnel from
other agencies. Accordingly, the chief of the Analysis and Warning Section,
which includes the AISU, and the AISU chief, at the

time of our review, were detailees from the intelligence community. NIPC
officials also attribute the limited progress of the Analysis and Warning
Section and the AISU to sustained leadership vacancies. According to NIPC
records, the Chief of the Analysis and Warning Section position, which was
to be filled by the Central Intelligence Agency (CIA), was vacant for about
half of the NIPC?s 3- year existence. Similarly, NIPC

records show that a National Security Agency detailee position was vacant
for approximately 17 months between May 1998 and April 2000. As a result,
the NIPC could not fully benefit from the experience of these intelligence
community officials in developing the required capabilities. In addition,
fewer detailees have been provided for other AISU positions than were
originally anticipated, and most positions have been filled with FBI
analysts. Since its creation in 1998 through the end of fiscal year 2000,
the AISU has operated with an average of about 13 analysts. Ten of these
positions have been held by FBI analysts, and three positions have been
held, sometimes on an intermittent basis, by detailees from other federal
agencies or from international partners, such as Canada and the United
Kingdom. An additional three detailee positions were designated by the

NIPC but were not staffed by the other involved federal agencies. In August
2000, the Analysis and Warning Chief estimated that the AISU needed about 24
analysts to provide a foundation for building adequate analytical
capabilities. This would allow the NIPC to devote about three analysts to
each of the eight industry sectors identified in PDD 63.

Through interviews with NIPC officials and individuals from other federal
agencies who had been detailed to or otherwise associated with the NIPC, we
identified two factors that contributed to agencies? not providing the
number of experienced detailees originally anticipated. First, federal
employees with experience in computer security and information

technology management are in short supply, and agencies need those

available to support their own operations. As a result, agencies are
reluctant to provide such valued staff to the NIPC. Second, of the 25
individuals we interviewed who had been detailed to the NIPC, 16 expressed
negative comments about their work experience there. In particular, the
detailees noted that FBI procedures prevented them from being involved in
decisionmaking and limited their access to information. Some of the
detailees felt that they were not provided the same level of respect and
support as were the FBI agents who were assigned to the

NIPC. For example, one detailee assigned to the NIPC for almost 18 months
during 1999 to 2000, observed that detailees had different badges, could not
access some computer systems, and could not sign procurement orders.
However, by the summer of 2000, the situation had improved; detailees were
given badges similar to FBI personnel, increased access to computer systems,
and authority to sign some procurement forms.

Although NIPC officials cited a need for more personnel, they also cited a
need for personnel with more experience and expertise in computers,
infrastructure operations, and intelligence analysis. NIPC officials said
that most of the FBI employees assigned to the AISU have had limited
expertise in these areas and have lacked the skills necessary to perform the
assigned

functions. The FBI?s 1998- 2003 Strategic Plan corroborated these
assertions, noting that FBI analysts often have had little or no training in
intelligence analysis and lack experience in the subject matter for which
they are responsible. According to one NIPC manager, additional expertise
could be obtained by hiring analysts from outside of the FBI. However, NIPC
officials say they have been precluded from doing so because the

NIPC must stay within the authorized FBI staffing levels. NIPC officials
said that this shortage of expertise and skills has especially limited the
NIPC?s ability to establish a viable strategic analysis capability, since
this requires sustained efforts over a period of time. FBI and NIPC
officials are

aware of this problem and, in 1998 and 2000, the Attorney General and the
FBI director wrote to agency heads requesting detailees. Also, in November
2000, the FBI Director sent a letter to the Assistant to the President for
National Security Affairs stating that ?without additional support from
other federal agencies, our ability to effectively detect, warn of, and
respond to cyber attacks will not be adequate to address the ever growing
threat.? In addition, NIPC officials told us they were developing a plan and
budget justification that detailed the need for an increase in NIPC staff.

Inadequate Data on The AISU?s strategic analysis capabilities depend to a
large extent on the Infrastructure Vulnerabilities

availability of technical infrastructure assessments that provide
industryspecific data on factors such as critical system components, known

vulnerabilities, and interdependencies. Under PDD 63, eight infrastructure
segments were to be assessed by each industry sector?s lead agency and
industry representatives. For example, the Department of Transportation was
directed to work with the transportation industry, and Commerce was to work
with the telecommunications sector to develop their respective sector
technical assessments. According to the National Plan, the NIPC was to use
these assessments in combination with foreign intelligence information,
information from law enforcement investigations and operations, and
voluntary private- sector

reports, to develop comprehensive strategic assessments of risk. According
to the Attorney General?s plan, such comprehensive assessments are important
because they are to form the basis for identifying indicators of potentially
malicious or damaging activity and developing related intelligence
collection requirements. In addition, these assessments provide input for a
variety of NIPC products, including alerts and advisories.

Most of the industry assessments have not, however, been performed, and none
have been provided to the NIPC. NIPC officials told us that assessments had
been at least partially performed for the electric power, transportation,
and water sectors. However, they had received no detailed written
assessments and, as a result, could not benefit from their findings. In
addition, in 2000, NIPC initiated assessments of telecommunications and

electric power. According to NIPC officials, these assessments were intended
to develop relevant products for the industry sectors and encourage sectors
to participate more in PDD 63. At the close of our review, these documents
remained in draft form.

The NIPC Has To provide a warning capability as required by PDD 63, the NIPC
Developed a

established the Watch and Warning Unit. The unit?s objective is to identify
attacks that appear imminent and alert government entities, businesses,
Rudimentary Warning

and the public, so that significant damage can be averted. While some
Capability

warnings have been issued in time to avert damage, most of the warnings,
especially those related to viruses, have pertained to attacks that were
already underway.

Several factors, some of which are beyond the NIPC?s control, have hindered
the NIPC?s ability to provide advance warnings. Specifically, no
comprehensive governmentwide or nationwide data- collection and analysis
framework has been established to provide the NIPC with

information on unusual or suspicious computer- based activity before the
occurrence of actual incidents. In addition, the Watch and Warning Unit?s
ability to issue warnings is slowed by a shortage of experienced watch

officers and the need to verify the accuracy of the input it receives and
ensure that sensitive information is protected.

Number of Warnings Has Since its establishment in 1998, the NIPC has issued
81 warnings that were Increased, but Value in based on the work of its Watch
and Warning Unit. Many of these alerts Protecting Systems Is

were posted on the Internet and were available to the public. Other alerts
Largely Unknown

were targeted to specific industries or individual organizations that the
NIPC deemed to be at special risk.

The NIPC categorizes its warnings as follows. The most serious is an
"alert," which provides information on a major threat or on imminent or
inprogress attacks targeting specific national networks or critical
infrastructures. The second most serious type of warning is an "advisory,"
which provides information on significant threats or incidents and suggests
that organizations strengthen their readiness posture. The third and least

serious type of warning is an "assessment," which provides broad, general
incident or issue awareness information that is both significant and current
but does not necessarily suggest immediate action. Before March 2000, the
NIPC issued notifications referred to as ?warnings,? which were similar to
what it now refers to as alerts. The NIPC deleted this category and added
the assessment category so that its warning system would more closely be
aligned with the FBI?s system for warnings about terrorist acts. In some
cases, multiple warnings are issued that pertain to only one type of attack

or incident. For example, in May, June, and August 2000, the NIPC issued
nine alerts on the ILOVEYOU virus and related variations. The number and
type of warnings issued by the NIPC in 1998 (February - December), 1999, and
2000 are summarized in table 1.

Table 1: Warnings Issued by the NIPC, 1998, 1999 and 2000 Number of warnings
Type of

1998 warning (Feb. - Dec. ) 1999 2000 Total

Alert 5 7 11 23 Advisory 1 18 14 33 Assessment a N/ A N/ A 11 11 Warning a 4
10N/ A14

Tot al 10 35 36 81

N/ A = not applicable a Before March 2000, the NIPC issued notifications
referred to as ?warnings,? which were similar to what it now refers to as
?alerts.? The NIPC deleted this category and added the assessment category
so that its warning system would more closely be aligned with the FBI?s
system for warnings about terrorist acts.

Source: GAO analysis of NIPC data.

Most of the NIPC?s warnings illustrated in table 1 pertained to attacks
underway; few preceded an imminent attack. One senior NIPC official noted
that the NIPC currently lacks the information and the necessary

understanding to identify discrete indicators that might be precursors to a
computer- based attack. As a result, most of its warnings are based on
reports of attacks in progress. However, in late 1999 and 2000, there were
several instances when the NIPC was able to provide warnings before an
attack was actually launched. These included the following examples:

 In April 2000, the NIPC obtained information from a law enforcement
investigation that 478 serious (root- level) compromises had been
perpetrated globally in an effort to create a distributed denial- of-
service attack. The NIPC coordinated efforts to warn victims, individually,
by

working with 11 FBI legal attachï¿½s located abroad and through the FBI field
offices in the United States. According to the NIPC, many victims had been
unaware of their systems? compromise before the warning.  In December 1999,
multiple reports of the presence of distributed

denial- of- service tools on computer systems in the United States prompted
the NIPC to issue an alert, its most urgent warning. According to the NIPC,
these tools were capable of generating sufficient network traffic to congest
targeted networks or systems, thus rendering them inoperable. The NIPC
supplemented its alert with a software program that system administrators
could use to detect the presence of denial- of- service attack tools on
their systems.

While the NIPC has issued warnings directly to hundreds of individuals and
entities, and made many of its alerts, advisories, and assessments publicly
available through its Web site, it does not have any reliable information on
the effectiveness of these warnings. For example, NIPC does not develop

statistics on the number of visitors to its Web site or routinely solicit
feedback on the effectiveness of its warnings from industry or the public.
NIPC officials told us that they informally solicit feedback and had
received a great deal of unsolicited feedback on NIPC products. They said
that further efforts in this area were constrained by limited resources.
Also,

they noted that a challenge inherent in providing warnings is that there is
no way to ensure that potential victims will hear or heed the warning. Watch
and Warning During the last half of 2000, the Watch and Warning Unit
formalized Procedures Formalized

standard operating procedures to guide the activities of watch officers.
During 2000 Before this, informal procedures had evolved as the unit gained
experience, but many had not been fully documented. In addition, many watch
officers were detailees from other agencies, and turnover of staff had been
rapid, making the need for standard, documented procedures especially
important.

The new procedures are intended to ensure that watch officers perform their
duties completely and consistently and establish standard criteria and
procedures for issuing warnings. As such, they describe watch officer
responsibilities and provide a detailed list of activities to be conducted
at specified intervals. The procedures also describe a carefully ordered
process for assessing an incident; convening a watch advisory committee;
developing alerts, advisories, and assessments; and disseminating warnings.

Barriers to Issuing Early Even when the NIPC becomes aware of an imminent
threat, four factors

Warnings hinder its ability to issue early warnings: (1) a lack of a
comprehensive

governmentwide or nationwide framework for promptly obtaining and analyzing
information on imminent attacks; (2) a shortage of skilled staff; (3) the
need to ensure that the NIPC does not raise undue alarm for

insignificant incidents; and (4) the need to ensure that sensitive
information is protected, especially when such information pertains to law
enforcement investigations underway.

No Comprehensive DataCollection Unlike watch and warning efforts for attacks
from nuclear and

and Analysis conventional weapons, which are supported by an array of
satellites and

Framework other data- collection and analysis mechanisms, no comprehensive

governmentwide or nationwide data- collection and analysis framework has
been established for (1) developing information on what constitutes unusual
or suspicious activity associated with computers supporting critical
operations, (2) recognizing such activity, and (3) promptly reporting

the activity to the NIPC or others for further analysis to determine if a
warning is appropriate. As a result, the Watch and Warning Unit develops its
warnings on the basis of analyses developed by the AISU, which it
supplements with information gathered from the Internet and from telephone
calls and e- mails from government and industry sources.

Officials involved in developing indications and warnings at DOD told us
that establishing more comprehensive and effective mechanisms for detecting
computer- based attacks are likely to take significant effort. According to
the 1996 Report of the Defense Science Board Task Force on Information
Warfare Defense, it took the United States over four decades to identify the
indicators for nuclear and conventional attacks and optimize

the collection and reporting systems to perform analysis needed for watch
and warning. Defense officials told us that developing reliable indications
of impending computer- based attacks would be even more difficult

because attacks can be launched by small, loosely aligned groups. Such
planned attacks are difficult to identify because the perpetrators do not
always have the bureaucratic organization or command and control structure
that allows their doctrine, organization, and capability to be

observed in advance of an attack. In addition, the ability of such groups to
quickly develop networks and maintain anonymity makes it very difficult to
create the types of predictive methodologies that have evolved for
monitoring traditional, noncyber threats.

Several federal efforts are planned or underway to develop warning
indicators and mechanisms for promptly communicating alert data. For
example, the NIPC and the electric power industry have developed a voluntary
set of reporting requirements and thresholds for voluntary

information sharing and data analysis. This "Indications, Analysis and
Warning" program, piloted in 1999, is intended to (1) establish computer
connectivity with electric power industry components, (2) develop agreedupon

criteria for attack indicators, and (3) implement criteria for information
sharing with the NIPC. (Chapter 4 of this report discusses in greater detail
the NIPC?s efforts to establish cooperative, informationsharing
relationships with government and private- sector sources.) In

addition, the National Security Agency?s National Security Incident Response
Center, which acts as a focal point for addressing computer incidents
affecting national security information systems, maintains a database on
computer incidents and their sources. In 1998, the response

center recorded more than 5, 700 computer incidents, which originated from
foreign and domestic sources. However, no such data- collection framework is
being developed on a governmentwide or national basis. Shortage of Skilled
Staff NIPC has difficulty staffing its 24- hour watch operations with
skilled staff. During 1999 and 2000, the Watch and Warning Unit had an
average of 12 employees, who monitored the Internet and other media to
identify reports on computer- based attacks. Initially, the unit operated 5
days a week, 16 hours a day. In December 1999, the NIPC initiated continuous
watch operations- 24 hours a day, 7 days a week. The NIPC?s goal is to have
four people on each 12- hour shift. NIPC officials said that they have not
met this goal because they have not had enough staff who possess an
understanding of the Internet and the implications of computer attack
techniques to recognize potentially serious incidents. Officials told us
that,

as a result, some shifts could not be adequately staffed. Avoiding Undue
Alarm While the NIPC considers all types of incidents and attacks, it is
important that the NIPC limit its public warnings to those that appear to
present significant risk. Computer- based attacks and other potentially
destructive

incidents are becoming more common, but, according to NIPC officials, most
incidents result in little or no significant damage. For example, officials
assert that approximately 20 to 30 new computer viruses are

disseminated daily, with over 50,000 known viruses being in existence. From
their experience, NIPC officials determined that most of these viruses did
not warrant a public warning because they were not very damaging, did not
propagate easily, or were readily detected by existing antivirus software.

Issuing too many warnings on incidents that ultimately do little or no harm
would diminish the NIPC?s credibility, and computer users might begin to
ignore important warnings. In May 2000, the NIPC Director stated that
?creating an unnecessary panic or perpetuating a virus hoax could be just as
damaging as a real virus if it caused people to unnecessarily disconnect
from the Internet or shut down e- mail.? 2 Accordingly, the NIPC takes time
2 Statement for the Record of Michael A. Vatis, NIPC Director, before the
Senate Committee on Judiciary, May 25, 2000.

to ensure that the reports it obtains are credible and to determine if
incidents, attacks, and viruses are significant enough, in terms of their
potentially destructive impact, to warrant a public warning. The procedures
defined by the NIPC in August 2000 state that analyzing a potential threat,
determining the need for a warning, and disseminating the warning can take
several hours and involve a wide range of contacts with NIPC personnel and
outside entities, including computer incident response centers and software
manufacturers.

The NIPC?s ability to perform such analyses in a timely manner is closely
linked to the extent of technical and analytical expertise that it has
available on a 24- hour basis. Shortfalls in such expertise have limited the
NIPC?s ability to promptly determine which incidents merit issuance of an
immediate warning.

Protecting Sensitive Information In many cases, the NIPC learns of a
computer- based threat from intelligence sources or as part of a criminal
investigation. In these cases, the NIPC takes special precautions to ensure
that warnings do not inappropriately disclose sensitive information, thus
balancing the need to

protect evidentiary data with the need to issue timely warnings. Such
precautions can be tedious and time- consuming. Before disseminating
national security or intelligence information, the NIPC works with the
originating agency to delete sensitive information, which is a process often
referred to as sanitizing the information. For example, to release
information from a classified source, such as an intelligence report, the
NIPC obtains permission from the analyst who wrote the report. Then,
according to NIPC officials, they must submit a draft of the sanitized
version to the originating intelligence analyst for review and release. This
process can involve several exchanges of drafts, thereby slowing the warning
process.

Sanitizing law enforcement information can also cause delay. According to
NIPC officials, while there is a common understanding about procedures for
handling classified information and the punishments for mishandling it,
there is no legal framework detailing how law enforcement sensitive
information is to be handled. As a result, many in the law enforcement
community are hesitant to share information with officials in the defense
and intelligence communities or with the private sector. Another deterrent
is that law enforcement sensitive information, such as classified
intelligence information, may impact undercover operations, and

mishandling it may seriously harm operations and place sources of
information at risk. Several officials we met with outside of the NIPC noted
the difficulty inherent in balancing the benefits of warning the public with
the benefits of protecting information needed to apprehend a perpetrator and
prosecute a criminal case. Investigations may yield unique information that,
when translated into warnings, can both prevent damage as well as help
identify

additional victims of a related attack. NIPC officials agreed and said that,
during 1999 and 2000, they have attempted to make warning a priority by
encouraging investigators and analysts to disseminate warnings that protect
law enforcement, while still providing industry and government information
needed to mitigate damage from computer- based attacks. According to NIPC
records, on 18 occasions from March 1999 through October 2000, the NIPC
issued warnings that were based on information

from ongoing criminal and foreign counterintelligence investigations.
However, in February 2001, the National Coordinator for Security,
Infrastructure Protection, and Counter- Terrorism told us that issues still
remained to be resolved to facilitate the sharing of such information. For

example, he asserted that, in some instances, it would be helpful if the
NIPC shared more information during the initial phase of an investigation so
that other federal entities can take appropriate action to protect their
operations.

Other Factors In addition to the impediments discussed, two significant
factors make it Impeding Development difficult to evaluate the NIPC?s
progress in developing analysis and warning

capabilities and may impact the viability of the government?s broader of
Analysis and strategy for protecting the nation?s critical infrastructures
from computerbased Warning Capabilities

attacks. The first factor is that the NIPC?s roles and responsibilities have
not been fully defined and are not consistently interpreted by other
entities responsible for critical infrastructure protection. The second

factor is that the NIPC has not developed a comprehensive, integrated plan
that describes its goals for developing analysis and warning capabilities
and the actions and related resources needed to achieve them.

Details of NIPC Roles and The government?s strategy and subordinate plans
for protecting the nation?s Priorities Inadequately critical infrastructures
from computer- based attacks, including the NIPC?s Defined and Communicated
role, have not been clearly articulated. While PDD 63 established December
2000 as the deadline for achieving an initial operating capability

and May 2003 for achieving full operational capability of key functions,
such as warning capability, neither the directive nor the subsequent
National Plan for Information Systems Protection defined what such
capabilities would include. PDD 63 describes general goals and provides an
outline of the responsibilities assigned to the NIPC, but the directive

provides few details regarding the NIPC role and its relationship to other
entities, especially those involved in analysis and warning for national
security. The National Plan provided little additional information
pertaining to the NIPC, noting that the plan ?will evolve and be updated as
we deepen our knowledge of our vulnerabilities and the emerging threats.?
Interpretation of NIPC?s Role Is

In a September 1998 report, shortly after the initial issuance of PDD 63, we
Not Consistent noted the importance of developing a governmentwide strategy
that clearly defines and coordinates the roles of new and existing federal
entities to ensure governmentwide cooperation and support for PDD 63. 3 At
that time,

we recommended that OMB, which, by law, is responsible for overseeing
federal information security, and the Assistant to the President for
National Security Affairs ensure such coordination. In written comments on
that

report and at a November 1998 meeting, senior officials involved in
implementing PDD 63 told us that plans for such coordination were being
implemented. However, our more recent meetings with representatives of the
entities involved in the government?s critical infrastructure protection
showed that they do not share a consistent interpretation of the NIPC?s
roles and responsibilities in these efforts.

PDD 63 outlines a central national role for the NIPC. Specifically, it says
the following: ?The NIPC will provide a national focal point for gathering
information on threats to the infrastructures. Additionally, the NIPC will
provide the principal means of facilitating and coordinating the federal
government?s response to an incident, mitigating attacks, investigating
threats and monitoring reconstitution efforts . ?

However, our discussions with officials in the defense, intelligence, and
civilian agencies involved in critical infrastructure protection, and with
OMB and the National Security Council showed that their views of the

NIPC?s roles and responsibilities differ from one another and, in some
cases, from those outlined in PDD 63. Several expressed an opinion that

3 Information Security: Serious Weaknesses Place Critical Federal Operations
and Assets at Risk (GAO/ AIMD- 98- 92, September 23, 1998).

this lack of consensus has hindered the NIPC?s progress and diminished
support from other federal agencies. Examples of their comments follow: 
The National Coordinator for Security, Infrastructure Protection, and

Counter- Terrorism, who is responsible for implementation of PDD 63, told us
that there is a conflict between the NIPC?s responsibilities to (1) broadly
gather, analyze, and share information on computer- based threats and (2)
support the FBI?s investigative activities, which usually preclude sharing
of information associated with cases under investigation. He said that this
conflict has impeded the NIPC?s ability to fulfill its analytical and
warning responsibilities and diminished the level

of support it has received from other agencies and the private sector. He
said that he believes the NIPC role should be limited to investigating
incidents.  OMB officials told us that they did not view the NIPC, as ?the?
national focal point for gathering information on threats, but as one of
several centers devoted to providing information on threats to U. S.
infrastructures. In addition, they said that the NIPC?s focus was to be on
law enforcement, as indicated by its placement within the FBI.  Officials
in the intelligence community said that they were uncertain what role the
NIPC was supposed to play, and several noted that, for

national security purposes, they viewed the NIPC as a second- tier
participant that primarily received finished intelligence, rather than an
organization that generated original, analytical products.  Several
officials involved in critical infrastructure protection efforts said that
PDD 63 envisioned that the NIPC would combine the strength of agencies
responsible for national defense, intelligence, and domestic

law enforcement. However, fulfilling this vision sometimes conflicts with
the FBI?s primary mission of apprehending criminals and bringing them to
justice. In particular, this conflict has led to questions about the NIPC?s
ability to lead response efforts should a widespread computerbased crisis
occur.

NIPC officials maintain that PDD 63 and the National Plan clearly outline
the functional responsibilities of the NIPC. Further, NIPC officials told us
that, in their view, some agency officials say the NIPC?s role is not
defined properly either as an excuse for not providing support in the form
of detailees or because the agencies believe that parts of the NIPC?s
mission

should be performed elsewhere. The FBI Director corroborated this in a
November 2000 letter to the Assistant to the President for National Security
Affairs in which he stated ?some agencies appear to question PDD 63 itself
and would like to take parts of the NIPC?s mission.?

Lines of Authority Are Not Clear It is unclear who has direct authority for
the NIPC, who sets its priorities and procedures, and who provides
oversight. PDD 63 states that the National Coordinator, who reports to the
Assistant to the President for National Security Affairs, shall be
responsible for coordinating the implementation of the directive.
Accordingly, the National Coordinator contends that responsibility for NIPC
oversight rests with him. However, because the NIPC is located within the
FBI and the NIPC Director is subordinate to an FBI Assistant Director, the
NIPC is also subject to FBI

direction. This situation may be impeding the NIPC?s ability to carry out
its mission. Examples include the following:

 The NIPC?s budget requests- including staffing and other financial
resources- are controlled by the FBI and the Department of Justice, raising
concern among NIPC officials that the NIPC?s priorities, which are intended
to reflect the interests of national critical infrastructure protection, may
be subordinated to the FBI?s law enforcement priorities.

NIPC officials told us that their repeated requests for additional resources
as part of the budget process had not been approved by the FBI.  Requests
for detailees of agencies, such as the Departments of State, Energy,
Defense, and the Treasury and the CIA, to support the NIPC

have come from the FBI and Justice, rather than from the National
Coordinator or the National Security Council, possibly raising questions
regarding whether the NIPC?s request for detailees had the full support of
the Executive Office of the President.  The NIPC proposal to create an
operational advisory board comprising

senior representatives from other agencies with key critical infrastructure
protection roles and intended to resolve several issues- including the need
for detailees and interagency expertise- was approved by the FBI Director
but subsequently rejected by the National Coordinator, leaving the issues
unaddressed.

 Existing agreements between the Executive Office of the President and
Justice restricting disclosure of law enforcement information have inhibited
the NIPC?s ability to share information with the National Coordinator. For
example, in a recent case, the NIPC Director was unable to share information
about an investigation with the National Coordinator until officials in
Justice had approved it.

The NIPC Has Not Been The NIPC?s role in providing warning has not been
integrated into the Integrated Into National Security

national security warnings process, which provide a means of alerting the
Warning Procedures

most senior federal officials, including the President, of serious or
imminent threats to national security. Such warnings are developed and
issued by the National Intelligence Council, which includes members from
each federal intelligence agency. According to the Attorney General?s
FiveYear Interagency Counterterrorism and Technology Crime Plan, the
National Intelligence Council, the Joint Chiefs of Staff, the National
Communications System, and the NIPC met in 1998 and 1999 to discuss

how the NIPC should be integrated into the national warning system. The goal
was to produce a warning system that met the requirements for national
defense, law enforcement, and intelligence. However, no consensus was
reached and no additional meetings were held. As a result, NIPC?s role has
not been formally recognized as part of the national security warning
procedures. Rules for Recognizing and The NIPC and the Defense and
intelligence communities have not Responding to a National developed (1)
criteria for determining when a computer- based attack Security Incident
Have Not Been should be treated as a national security event rather than as
a crime and (2)

Established protocols for placing the NIPC in a support role, rather than a
lead role,

should such a national security event occur. While computer- based attacks,
to date, have not caused devastating damage and have not been treated as
acts of war, NIPC and DOD officials agree that, under certain circumstances,
such an attack could constitute an act of war or other immediate threat to
national security. PDD 63 recognized that, should an incident be deemed a
threat to national security, responsibility for coordinating the response
would fall to DOD or the intelligence community. Specifically, PDD 63 stated
that, ?depending on the nature and level of a foreign threat/ attack,
protocols established between special function agencies (DOJ/ DOD/ CIA), and
the ultimate decision of the President, the NIPC may be placed in a direct
support role to either DOD or the Intelligence Community.? Accordingly, NIPC
officials

said that there is a need to establish response protocols that will
differentiate between national security concerns, criminal activity, and
malicious mischief. DOD?s Director for Information Assurance agreed, stating
that, without such protocols, a national security crisis may not be
recognized and addressed in a timely manner.

While some legal provisions and detailed protocols exist for placing the FBI
in support of DOD for responses to terrorism, it is not yet certain whether
the same provisions would apply to computer- based attacks. Such provisions
and protocols are important because they provide, under certain
circumstances, exemptions from prohibitions of the Posse Comitatus Act, 4
which bars DOD from participating in domestic law enforcement activities. A
number of statutory exemptions permit DOD?s involvement in dealing with
domestic terrorist incidents. For example, if an exceptionally grave
physical terrorist threat or incident exceeds FBI capabilities, a special
operations task force may be established that places DOD in the lead and the
FBI in a support role. According to Justice officials, these statutory
exemptions often require a request from the Attorney General; concurrence by
the Secretary of Defense; and, as a matter of policy, in most instances,
approval by the President. To initiate this process, the President

must issue an executive order and a proclamation- documents that are
maintained in draft form so that they are ready for the President?s
signature, if needed. 5 Senior NIPC officials told us that they intended
that the operational advisory board that they had proposed establishing
during 2000 would examine the existing protocols developed for physical
terrorism and determine if they were sufficient in the event of a serious
computer- based attack or if new protocols were needed. However, as
previously mentioned, the National Coordinator turned down this proposal,
and, as of

December 2000, Defense and intelligence officials told us that there were no
efforts underway to resolve this issue. The NIPC Has Not An additional
factor impeding evaluation of its progress is that, as of Integrated Plans
for December 31, 2000, the NIPC had not developed a comprehensive,
Developing Analysis and integrated plan outlining its goals for developing
analysis and warning

Warning Capabilities capabilities and identifying needed resources. Instead,
it has developed

elements of a plan, which are contained in a variety of different documents.
These include the following: 4 The Posse Comitatus Act, Title 18 U. S. C.
1385. 5 Combating Terrorism: Federal Agencies? Efforts to Implement National
Policy and Strategy (GAO/ NSIAD- 97- 254, September 26, 1997).

 In 1999, the FBI outlined general goals and challenges related to
developing analysis and warning capabilities in the National Infrastructure
Protection and Computer Intrusion Program Plan. This plan recognized the
need to (1) institutionalize a process for receiving real- time information
relative to threats, incidents, and vulnerabilities pertaining to critical
infrastructures and (2) develop analytical and communications skills and
expertise in computer technologies. An updated version of the plan was
issued in October 2000. However, both the 1999 plan and the 2000 update
focus primarily on investigative capabilities being developed in FBI field
offices.  In 1999, the Attorney General?s Five- Year Interagency
Counterterrorism

and Technology Crime Plan provided detailed information on the intended
operations of the NIPC, including analysis and warning as well as the
identification of indicators. It also recognized that the

development of NIPC capabilities was highly dependent on interagency
cooperation.  In 2000, the NIPC drafted the National Infrastructure
Protection Center Priorities and Goals 2000- 2002 document, which was
intended for approval and input from a proposed advisory board. The document
contains an outline of goals and objectives for analysis and warning
capabilities, but does not address the interim steps needed to achieve

them.  In 2000, the Analysis and Warning Section developed seven detailed
goals and related objectives for fiscal year 2001. However, this document
did not provide an explanation or strategy on how NIPC

would achieve them.  NIPC officials provided us documents they say were
used to support

their 1999, 2000, 2001 budget requests for analysis and warning efforts.
These documents identify resources, strategies and current shortfalls.

While these documents provide information on the NIPC?s general plans and
needed resources, the information is fragmented and incomplete. As a result,
it does not provide a comprehensive road map to guide,

communicate, and measure progress. Such plans are also important because
they serve to clarify and communicate objectives and goals. In addition, the
plans can highlight potential problems, describe resource needs, and provide
a means for measuring performance. The Government Performance and Results
Act of 1993 6 required federal agencies to develop strategic plans that
included six key elements. Although that act does not

6 P. L. 103- 62, August 3, 1993, sec. 3 (5 U. S. C. 306).

require such plans for individual agency programs, the following six key
elements it identifies serve as a useful guide:

 a comprehensive agency mission statement;  general goals and objectives
for all major functions and operations;  a description of how the goals and
objectives are to be achieved,

including operational processes, skills, and technology and the human
capital and other resources needed;  a description of the relationship
between the general goals and

objectives and annual performance goals;  identification of key factors,
external to the agency and beyond its

control, that could significantly affect the achievement of the general
objectives and goals; and  a description of how program evaluations were
used to establish or revise general objectives and goals, and a schedule for
future program

evaluations. The documents described above contained some of these elements;
however, they did not (1) establish milestones and performance measures; (2)
describe the specific operational processes, skills, and technology
necessary to achieve the stated goals and objectives; (3) describe the
relationship between the general goals and objectives and annual NIPC

performance goals; and (4) describe how program evaluations would be used to
establish or revise general objectives and goals and a schedule for future
program evaluations.

Changes to NIPC At the close of our review, in February 2001, the National
Coordinator told Responsibilities Being us that the administration had begun
to consider options for adjusting the

Considered federal strategy for critical infrastructure protection
originally outlined in PDD 63. He said that adjustments being considered
included provisions

related to the development of analysis and warning capabilities currently
assigned to the NIPC and that one intent of any such changes would be to
clarify roles and responsibilities in this area. Conclusions While the NIPC
has taken some steps to develop analysis and warning

capabilities, the strategic capabilities described in PDD 63 have not been
achieved. Many of the factors that have impeded the NIPC?s progress in this
area, such as the absence of a methodology for strategic threat analysis,
the lack of needed staff and expertise, and inadequate data on
infrastructures, will require coordinated information- sharing and analysis

efforts by the federal agencies that have pertinent expertise. Similarly,
the NIPC efforts in warning have also been impeded by the lack of a
comprehensive, governmentwide data- collection framework for identifying
imminent computer- based attacks. Further, the NIPC faces other barriers in
issuing timely warnings, including a shortage of skilled staff, avoiding
undue alarm for insignificant incidents, and ensuring that sensitive
information is protected. Evaluating the NIPC?s progress is difficult
because its roles and

responsibilities have not been fully defined and are not consistently
interpreted by other entities responsible for critical infrastructure
protection. Specifically, it remains unclear who has direct authority for
the NIPC and if the NIPC is to be integrated into the national security
warning process. Further, no criteria have been developed for determining
when a computer- based incident threatens national security and what related
protocols would be used to place the NIPC in support of DOD or the
intelligence community. Clarifying such issues and engendering
governmentwide support and assistance will be important elements of ensuring
the successful development of the analysis and warning capabilities
envisioned by PDD 63. In addition, developing a

comprehensive, integrated plan to guide activities related to establishing
analysis and warning capabilities, outline related resource needs, and
identify impediments to progress would provide valuable input for
consideration as the government moves forward with efforts to protect
critical infrastructures.

Recommendations for On the basis of the criteria provided in PDD 63 and
related plans, we

Executive Action recommend that the Assistant to the President for National
Security

Affairs, in coordination with pertinent executive agencies,  establish a
capability for strategic analysis of computer- based threats, including
developing a related methodology, acquiring staff expertise, and obtaining
infrastructure data;  develop a comprehensive governmentwide data-
collection and analysis framework and ensure that national watch and warning
operations for

computer- based attacks are supported by sufficient staff and resources; and
 clearly define the role of the NIPC in relation to other government and

private- sector entities, including  lines of authority among the NIPC and
the National Security Council,

Justice, the FBI, and other entities;

 the NIPC?s integration into the national warning system; and  protocols
that articulate how and under what circumstances the

NIPC would be placed in a support function to either the DOD or the
intelligence community.

We recommend that the Attorney General task the FBI Director to require the
NIPC Director to develop a comprehensive written plan for establishing
analysis and warning capabilities that integrates existing planning elements
and includes

 milestones and performance measures;  approaches (or strategies) and the
various resources needed to achieve the goals and objectives;

 a description of the relationship between the long- term goals and
objectives and the annual performance goals; and  a description of how
program evaluations could be used to establish or revise strategic goals,
along with a schedule for future program

evaluations. Agency Comments and

In commenting on a draft of this report, the Director of the NIPC generally
Our Evaluation

agreed with the report?s findings and stated that the NIPC considers it of
the utmost urgency to address the shortcomings identified. The Director
expressed the view that it is most important that the NIPC receive adequate
staffing, particularly from the defense and intelligence communities, to
address the lack of strategic analysis. In particular, the Director said
that the report should reflect that many executive branch components had not
heeded the call set out in PDD 63 to ?provide such assistance, information
and advice that the NIPC may request.? In addition, the Director recommended
that the report recognize the NIPC?s performance in the

context of its recent formation, noting that the NIPC has been in existence
for only 3 years. Finally, the Director noted that our report did not
recommend a change to the basic PDD 63 framework. In this regard, he

expressed the view that the FBI is the only locus where law enforcement,
counterintelligence, foreign intelligence, and private- sector information
may be lawfully and collectively analyzed and disseminated, all under
welldeveloped statutory protections and oversight of the Department of
Justice. The Director?s letter did not comment on our recommendations to the
NIPC regarding the need for a comprehensive, integrated plan for developing
analysis and warning capabilities.

The NIPC?s comments regarding the need for additional staff largely
reiterate our findings, which note that the NIPC has not received the
anticipated number of detailees from other executive departments. In
addition, our report repeatedly notes that the NIPC was established in early
1998. We have no additional information to add on these two topics.

Further, as the NIPC Director states, we did not recommend a change to the
basic PDD 63 framework, including changing the placement of the NIPC. We did
not make such a recommendation because moving the NIPC from the FBI to
another agency or establishing it as a stand- alone entity would not
necessarily ensure that the deficiencies we identified would be addressed.
These deficiencies, which included lack of a generally accepted

methodology for strategic analysis, lack of data on infrastructure
vulnerabilities and incidents, and insufficient staff resources, are
problems that need to be addressed regardless of the NIPC?s organizational

placement. The Special Assistant to the President and Senior Director for
Legislative Affairs at the National Security Council also provided comments,
saying that our report highlighted the need for a review of the roles and
responsibilities of the federal agencies involved in U. S. critical
infrastructure protection support. The comments stated that the
administration will consider our recommendations as it reviews federal

cyber activities to determine how the critical infrastructure protection
function should be organized. The Special Assistant to the President noted
that some functions might be better accomplished by distributing the tasks
across several existing federal agencies, creating a ?virtual analysis
center? that would provide not only a governmentwide analysis and reporting
capability, but that could also support rapid dissemination of cyber threat
and warning information.

The comments from the NIPC and the National Security Council are printed in
full in appendixes I and II, respectively.

The NIPC Has Provided Valuable Support and Coordination in Improving
Investigation and

Bri ef ng Chapt i Sect ons i er 3 Response Capabilities PDD 63 directed the
NIPC to provide the principal means of facilitating and coordinating the
federal government's response to computer- based incidents, mitigating
attacks, and monitoring reconstitution efforts. In response, the NIPC has
undertaken efforts in two major areas.

First, the NIPC has provided coordination and technical support to FBI field
offices, which have established special squads and teams and one regional
task force to address the growing number of computer crime cases. The NIPC?s
support has provided benefits, but activities in several areas have not yet
met expectations outlined in the FBI?s April 1999

National Infrastructure Protection and Computer Intrusion Program Plan. For
example, insufficient computer capacity and data transmission capabilities
have limited the NIPC?s ability to perform technical analyses quickly. In
addition, FBI field offices are not yet providing the NIPC with the
comprehensive information that NIPC officials say is needed to facilitate
prompt identification and response to such cyber incidents.

Second, the NIPC has developed crisis management capabilities to support a
multiagency response to the most serious incidents. Procedures for
establishing crisis- management teams have been developed and, on the basis
of experience with actual incidents, refined. In addition, the NIPC has
developed a draft emergency law enforcement sector plan to guide the
response of federal, state, and local entities. As of mid- February 2001,
the draft plan was being reviewed by law enforcement sector members.

Regarding the requirement that the NIPC develop capabilities to ?monitor
reconstitution? of computer systems, NIPC officials told us that virtually
nothing has been done because specific expectations for the NIPC in this
area have not been defined. The National Coordinator for Security,

Infrastructure Protection, and Counter- Terrorism agreed that the NIPC?s
specific role in this area was not clear and said that this issue would
probably be addressed as the administration reviews the government?s
critical infrastructure protection strategy and the specific requirements of
PDD 63.

The NIPC Has Since 1998, FBI investigative units and the NIPC have worked
together to Provided Coordination address the growing number of computer
crime cases, which federal law

enforcement guidelines define as attacks on computer systems for the and
Technical Support

purpose of acquiring information or to damage or disrupt the target to FBI
Field Squads computer system. Such cases do not include computer-
facilitated crimes, such as Internet fraud, e- mail extortion, or child
pornography, which are

handled by other FBI investigative programs. The NIPC?s support has provided
benefits, but activities in several areas have not yet met expectations
outlined in the National Infrastructure Protection and Computer Intrusion
Program Plan.

Increase in Computer According to the FBI Director and NIPC officials, the
number of computer

Crime Cases Has crime cases more than doubled from fiscal years 1998 to
2000, as shown in

table 2. NIPC officials estimate that the number of pending cases for such
Prompted the Need for crimes will increase to 3, 150 by fiscal year 2002.
Increased

Coordination and Technical Support

Table 2: Computer Crime Cases From FY 1998 to FY 2000 (all numbers are as of
October 1)

Case status FY 1998 FY 1999 FY 2000

Opened 540 801 1, 132 Closed 399 912 834 Pending 453 795 1, 123 Source: NIPC
officials.

In addition to increasing in numbers, computer crime cases tend to be
technically complex and resource- intensive to investigate, frequently
involving more than one state or nation and often requiring coordination of
efforts by many FBI field offices and other law enforcement entities. In
February 1998, one such multiagency investigation demonstrated the need for
an interagency center like the NIPC to coordinate investigative

activities that relate to potentially serious intrusions. The investigation,
referred to as Solar Sunrise, involved a series of related intrusions into
more than 500 military, civilian government, and private- sector computer
systems. Because the intrusions took place during the build- up of U. S.
military personnel in the Middle East in response to tensions with Iraq and
because the source of the intrusions could not immediately be determined,
the episode raised serious national security concerns. The FBI worked
closely with Israeli law enforcement authorities to solve the case, and,

within several days, the investigation determined that juveniles in
California and individuals in Israel were the perpetrators. Other cases
illustrating the need for coordination include investigation of the ILOVEYOU
virus in 2000, which involved 50 FBI agents from various locations and
coordination with the government of the Philippines, and

investigation of a denial- of- service attack in late 1999, which involved
36 FBI field offices and 13 legal attachï¿½s, who are FBI agents stationed
abroad. In addition, the cases identified in table 2 include 12 foreign
counterintelligence cases, which, according to NIPC officials, usually
require more time- consuming technical analysis- 2 such cases took over

18, 000 hours of analysis. At the end of fiscal year 2000, over 15 percent
of the 1,123 pending computer crime investigations were being conducted
jointly with other investigative agencies.

FBI Field Squads and In October 1998, the FBI created the National
Infrastructure Protection and

Regional Task Force Computer Intrusion Program to strengthen its ability to
investigate Established to Facilitate

computer- based attacks on critical infrastructures and tasked the NIPC to
Investigations

provide administrative and operational support. The program called for the
establishment of special squads, referred to as NIPC squads, in the FBI
field offices to serve as centers of expertise for investigating computer
crime. The National Infrastructure Protection and Computer Intrusion Program
Plan set a goal of establishing an NIPC squad in each FBI field office by
2003.

As of December 31, 2000, the FBI had established such squads, each
consisting of approximately 8 FBI agents, in 16 of the FBI?s 56 field
offices. In addition, 40 smaller teams of from 1 to 5 agents, dedicated to
working computer crime cases, have been established in other FBI field
offices. These squads and teams have served as focal points for computer
crime investigations in their regions. The number of agents assigned to the
NIPC squads has increased from 76 agents in fiscal year 1998 to
approximately 200 agents in fiscal years 1999 and 2000, most of these agents
were

transferred from other FBI investigative programs. While the NIPC provides
support and coordination, the NIPC squads are under the FBI field offices?
direct supervision. Accordingly, the field offices determine when a case is
to be opened and whether an incident needs to be referred to other federal,
state, or local law enforcement entities. In addition, FBI field offices are
usually the first to be alerted to potential

computer crime cases, most often by victims or informants. Generally, the
NIPC becomes involved when notified by the field squads through
caseinitiation paperwork, requests for technical assistance or direct
notification by telephone.

The National Infrastructure Protection and Computer Intrusion Program Plan
also called for the NIPC field squads to establish interagency task

forces to coordinate investigative work and facilitate information sharing
and coordinate investigations regarding computer crimes with other law
enforcement entities. As of December 31, 2000, only one task force had

been created. However, NIPC officials expected the task force to serve as a
model for similar task forces in other locations. Comprising representatives
from Justice, the U. S. Postal Service, Secret Service, Defense Criminal
Investigative Service, Internal Revenue Service, and state and local law
enforcement entities, the task force was established

in March 2000 in the FBI?s Pittsburgh field office. Since then, the task
force has undertaken several efforts that NIPC officials and task force
members agree have improved computer crime investigative capabilities in
that region. For example, the task force has  investigated 28 cases jointly
with other law enforcement entities-

accounting for approximately 15 percent of the FBI?s 177 joint computer
crime cases;  briefed other members of the law enforcement community and
private

industry on investigative techniques, including the handling of electronic
evidence related to computer crime;  sponsored development of a computer
laboratory to facilitate

collaboration on investigations and leverage resources donated by member
agencies, including computers and analytical tools; and  served as a forum
for discussing common challenges and issues.

NIPC Support Has Provided The NIPC has benefited computer crime
investigations by (1) coordinating Benefits

investigations among FBI field offices, thereby bringing a national
perspective to individual cases; (2) providing technical support in the form
of analyses, expert assistance for interviews, and tools for analyzing and

mitigating computer- based attacks; and (3) providing administrative support
to NIPC field agents. For example, the NIPC reports that it has

 produced over 250 written technical reports 1 during 1999 and 2000, over
80 percent of which supported investigations led by other law enforcement
agencies;

1 These technical reports were developed as part of computer intrusion
investigations and focus on the technical attributes of the intrusion,
including the vulnerabilities exploited and steps taken during the
intrusion. This focus on the specific details of individual

investigations distinguishes these technical reports from the analytical
reports produced by the AISU and discussed in chapter 2 of this report.

 responded to an average of six requests per day for technical analysis; 
developed analytical tools- some of which are classified- to assist in

investigating and mitigating computer- based attacks, including both
original software and modified commercial software;  created and posted
software tools, including tools issued in December 1999 and May 2000, for
detecting the presence of denial- of- service

software, one of which was downloaded 1, 200 times in one 24- hour period,
indicating that it was widely used;  managed the procurement and
installation of hardware and software tools for each of the NIPC field
squads and teams;

 managed development of a data warehousing project, referred to as the
Early Warning System, which is intended to link numerous sources of
electronic information so that they can be searched as a single entity,
thereby facilitating searches and accelerating investigations- a capability
that, according to officials, will also benefit tactical and

strategic analysis;  provided legal guidance and coordination with Justice
units and assisted

in obtaining the necessary court orders to conduct data intercepts; 
analyzed case- initiation paperwork to identify cases with similarities so
that they could be coordinated;

 identified and shared improved investigative techniques regarding computer
crime; and  streamlined administrative procedures for the increasing number
of

foreign counterintelligence cases, such as the recent investigations into
the possible theft of nuclear secrets from the Los Alamos National
Laboratory. Examples of significant cases that the NIPC has coordinated or
supported include the following:  In March 1999, the NIPC coordinated the
FBI field office investigation

into the Melissa macro virus, which caused an estimated $80 million in
losses. Although the Melissa virus did not actually destroy or alter data,
it generated large volumes of e- mail that congested and shut down
computers. Within less than a month, the virus? author was arrested.  In
June 1999, the NIPC coordinated an investigation of a Trojan horse

virus, referred to as the Explore. Zip worm, with six FBI field offices. The
virus had infected various private- sector computer systems and propagated
through the Internet via an e- mail attachment, destroying certain files on
computer hard drives. At the close of our review, the investigation had been
ongoing for over a year.

 From January to March 2000, the NIPC supported an investigation of two
teenagers who had used a computer in the United Kingdom to break into e-
commerce sites in five countries and steal information resulting in
estimated losses totaling over $3 million. The case, referred to as
?Curador,? was based on investigative work by the FBI and police in the
United Kingdom and Canada. The perpetrators were arrested and charged in the
United Kingdom in March 2000.

Problems Affecting the The National Infrastructure Protection and Computer
Intrusion Program

NIPC?s Effectiveness in Plan and the NIPC budget justifications identified
several deficiencies that Supporting Investigative

are impeding the NIPC?s ability to coordinate and support investigations of
Efforts computer crime cases. First, according to NIPC officials, delays had
occurred because the NIPC?s Special Technologies and Applications Unit did
not have computers capable of rapidly analyzing the large amounts of

data associated with some cases. Recent investigations have required the
unit to collect and analyze multiterabytes of data (equivalent to one or
more times the amount of information contained in the Library of

Congress). However, to analyze these data on its existing equipment, they
must be broken into segments and examined separately because the unit?s
computer capacity was insufficient to handle the large amount of data.
According to NIPC officials, the inadequacy of its current computer system
is contributing to a 30- day backlog in meeting requests for analysis from
the field offices.

In addition, agents in some field offices told us that they lack the means
to securely transmit large amounts of data between field offices and the
NIPC for analysis. These factors prolong the time needed to transmit and
analyze data and have contributed to the backlog of analyses that need to be
performed. According to NIPC officials and internal budget documents,
funding for additional computer equipment will be requested for fiscal year
2002.

Further, NIPC field squads are not reporting all of the information they
have on unusual or suspicious computer- based activity to the NIPC. The
National Infrastructure Protection and Computer Intrusion Program Plan
states that it is imperative that all field offices document and report all
complaints regarding computer intrusion activity and forward the information
to the NIPC. NIPC officials told us that receiving such comprehensive
information provides the NIPC with a broader and more complete view of
suspicious and unusual activity and facilitates prompt identification of
potentially widespread problems. Such information is of

value to the NIPC?s analysis and warning functions as well as its support of
NIPC investigations. However, NIPC field squad members told us that minor
incidents that did not merit opening a case were not always reported to the
NIPC because many incidents were deemed to be insignificant.

To provide an increased incentive for sharing information, the NIPC
established new performance measures for fiscal year 2001 so that field
squads receive credit for the amount of information shared about potential
cyber incidents, regardless of whether or not a case is opened.

Crisis Management According to the Attorney General?s Five- Year Interagency
Plans Have Been

Counterterrorism and Technology Crime Plan, as the lead entity responsible
for coordinating the federal government?s crisis management Developed and
response to computer- based attacks, the NIPC must be able to respond
quickly in the initial stages of a crisis situation and pursue the
appropriate law enforcement or national security strategies. The NIPC?s
primary efforts to fulfill these responsibilities have been related to
developing procedures for implementing crisis action teams in response to
computerbased

attacks and intrusions. Since 1998, the NIPC has formed seven such teams,
comprising a combination of NIPC personnel- agents and detailees, which have
responded to a range of classified and unclassified events lasting from a
day to over a year. Generally, these teams have served as the focal point
for coordinating the investigation and response to incidents with national
impact, including the Melissa virus in April, May, and June

1999; the transition to the year 2000; and denial- of- service attacks in
February and March 2000. In 1999, the FBI established an expanded Strategic
Information Operations Center, a crisis management center at FBI
headquarters, which has provided the teams with a collaborative working
environment and access to information through computer and
telecommunications support.

In August 2000, the NIPC standardized its procedures for initiating crisis
action teams and developed a detailed concept of operations to guide future
response. The detailed document identifies thresholds for activating crisis
teams, delineates the missions of the team members, and provides a framework
for involving individuals from the NIPC and other agencies. In addition, the
NIPC has drafted an emergency law enforcement sector plan. PDD 63 designated
Justice and the FBI as the lead agencies for the emergency law enforcement
services sector, and the FBI delegated this responsibility, including
development of the sector plan, to the NIPC. The

plan covers the roles and responsibilities for the more than 18, 000 law
enforcement agencies throughout the United States that the NIPC says have
volunteered to participate. In addition, the plan describes approaches for
assessing the vulnerability of critical law enforcement systems,

developing remediation and mitigation plans, and improving awareness of law
enforcement personnel. As of mid- February 2001, the NIPC had provided the
draft plan to sector members and was awaiting their comments.

In addition to the NIPC?s crisis management efforts, in July 2000, the
National Coordinator for Security, Infrastructure Protection, and
CounterTerrorism created two new entities involving the NIPC that are
designed to improve federal policymaking and response to computer- based
attacks. The Cyber Incident Steering Group is responsible for determining
the appropriate policy for response, and the Cyber Incident Working Group is
responsible for executing and coordinating a response. The National
Coordinator chairs the steering group, of which the NIPC Director is a

member, while the NIPC Director chairs the working group. According to a
process defined by the National Coordinator, the NIPC Director is to convene
the working group when an unauthorized cyber event occurs that has a
significant national security, economic, or public safety impact. The
working group is primarily to share information on

specific incidents and discuss related mitigating actions. In addition to
the NIPC Director, the group?s membership includes the Commander of the
Joint Task Force for Computer Network Defense, U. S. Space Command; the
Program Director of the Federal Computer Incident Response Capability, the
General Services Administration (GSA); and the Chief, Defensive Information
Operations Group at the National Security Agency.

Other agency representatives may be added, as appropriate. At the close of
our review, the Cyber Incident Working Group had convened once, in November
2000, to discuss issues related to hostile computer- based activity in the
Middle East.

Requirements for PDD 63 states that there will be a system to rapidly
reconstitute the

Monitoring minimum required capabilities after an infrastructure attack, and
it specifically assigns the NIPC responsibility for monitoring
reconstitution.

Reconstitution Have The National Plan states that the NIPC?s responsibility
in this area includes

Not Been Defined monitoring reconstitution of telecommunications and
computer networks on which the government relies.

NIPC officials told us that they have not planned or taken any action in
this regard because specific expectations for meeting the requirements
briefly mentioned in PDD 63 and the National Plan have not been further
defined. As a result, while the NIPC has established procedures for crisis
management teams, previously discussed, it is not clear what
responsibilities these teams would have regarding any reconstitution

efforts that may be needed as the result of a seriously damaging attack. The
National Coordinator for Security, Infrastructure Protection, and Counter-
Terrorism agreed that the NIPC?s specific role in this area was not clear
and said that this issue would probably be addressed as the administration
reviews the government?s critical infrastructure protection strategy and the
specific requirements of PDD 63.

Conclusions The NIPC has provided important support in increasing the FBI?s
ability to investigate computer crimes by coordinating investigations and
providing technical assistance. However, at some locations, insufficient
computer and communications capabilities have hindered the NIPC?s ability to
promptly and efficiently analyze large amounts of data in support of
investigations, and FBI field office personnel are not providing the NIPC

with all of the information they have on potentially damaging or hostile
computer- based activity. The NIPC has also developed crisis management
procedures and drafted an emergency law enforcement sector plan, which is
currently being reviewed by sector members. In 2000, the National
Coordinator supplemented these efforts by establishing the Cyber Incident
Steering Group, to develop response policies, and the Cyber Incident

Working Group, which is responsible for executing and coordinating a
response. No actions had been taken to develop capabilities to monitor
reconstitution of computer systems because specific expectations for the
NIPC in this area have not been defined. Recommendations for

To ensure that the NIPC develops the response, investigative, and crisis
Executive Action management capabilities required by PDD 63, we recommend
that the Attorney General direct the FBI Director to task the NIPC Director
to

 ensure that the Special Technologies and Applications Unit has access to
the computer and communications resources necessary to analyze data
associated with the increasing number of complex investigations;

 monitor implementation of new performance measures to ensure that they
result in field offices' fully reporting information on potential computer
crimes to the NIPC; and  complete development of the emergency law
enforcement plan, after comments are received from law enforcement sector
members.

As the national strategy for critical infrastructure protection is reviewed
and possible changes considered, we recommend that the Assistant to the
President for National Security Affairs define the NIPC?s responsibilities
for monitoring reconstitution.

Agency Comments and In commenting on a draft of this report, the Director of
the NIPC expressed

Our Evaluation the view that, despite formidable hurdles, the NIPC has
achieved

remarkable success, noting the establishment of a nationwide program for
investigating computer crime in 56 FBI field offices. He also said that the
NIPC, in conjunction with the Emergency Law Enforcement Sector Forum, had
developed the only sector infrastructure protection plan, which was
delivered to the National Coordinator in March 2001. The Director?s comments
did not address our recommendations to the NIPC regarding the

need to (1) ensure that the Special Technologies and Applications Unit had
access to adequate computer and communications resources and (2) monitor
implementation of new performance measures regarding field office reporting
of information on potential computer crimes.

Our report describes the National Infrastructure Protection and Computer
Intrusion Program, under which NIPC units in 56 FBI field offices have been
established, and the report commends the NIPC for providing

valuable coordination and technical support to this program. Our report also
credits the NIPC with leading development of the Emergency Law Enforcement
sector plan. We did not review the progress of other infrastructure sectors
in developing similar plans because such efforts were not within the scope
of our review. As a result, we cannot compare progress on the Emergency Law
Enforcement sector plan with progress on similar plans for other
infrastructure sectors.

In commenting on a draft of this report, the Special Assistant to the
President and Senior Director for Legislative Affairs at the National
Security Council said that our comments would be considered as the
administration reviews federal cyber activities to determine how the
critical infrastructure protection function should be organized. The

comments did not specifically address our recommendation that the NIPC?s
responsibilities for monitoring reconstitution be defined. The comments from
the NIPC and the National Security Council are printed in full in appendixes
I and II, respectively.

Progress In Information Sharing And

Chapt er 4

Outreach Has Been Mixed To help ensure that computer- based attacks are
promptly detected and that mitigation and recovery efforts are effective,
PDD 63 calls for extensive cooperation and information sharing among
government and private- sector entities. According to the January 2000
National Plan for Information

Systems Protection, the role of the federal government is to (1) create
federal capabilities for enhanced information sharing and (2) encourage
nonfederal entities (the private sector and state and local governments) to
organize themselves for efficient information exchange about cyber threats
and incidents. The National Plan further states that ?the NIPC has a vital
role in collecting and disseminating information from all relevant sources?
and that it is to accomplish this by ?establishing a network of
relationships with entities in both the government and the private sector.?
Since 1998, the NIPC has undertaken a range of initiatives designed to

foster information sharing among private- sector, government, and
international entities with mixed results. Regarding the private sector, the
NIPC has developed a collaborative relationship with the electric power
industry, but two- way information- sharing relationships between the NIPC

and other information- sharing and analysis centers has not developed. In
addition, the NIPC has increased the membership of its InfraGard Program,
which is designed to build direct relationships with individual companies,
but has made limited progress in developing its Key Asset Initiative, which
is designed to create a database of critical infrastructure components,
including those that are privately controlled. NIPC efforts to establish
information- sharing and coordination

relationships with other government entities have met with less success.
Federal agencies have not routinely reported incident information to the
NIPC, DOD and the NIPC agree that their information sharing needs
improvement, and Secret Service expertise has not been integrated into the
NIPC efforts. However, NIPC efforts to provide training on investigating
computer crime, which it views as an element of its outreach efforts, have
involved an increasing number of personnel from federal, state and local,

and international entities, and the NIPC has participated with several other
countries in infrastructure protection efforts.

Information Sharing Information sharing and coordination among organizations
are key And Coordination Are elements in developing comprehensive and
practical approaches to

defending against cyber threats. Having information on threats and actual
Essential To Combat incidents experienced by others can help an organization
better understand

Cyber Attacks, But the risks it faces and determine what preventive measures
should be

Present Challenges implemented. In addition, prompt warnings can help an
organization take immediate steps to mitigate an imminent attack.
Information sharing and coordination are also important after an attack, to
facilitate recovery and

criminal investigations. In July 2000, 1 we testified on the importance of
information sharing on cyber threats and related challenges, noting that
creating partnerships for information sharing and coordination is a
formidable task. Most important,

trust must be established among parties who may have varying interests and
expectations. For example, private- sector entities are usually motivated by
business concerns and profits, whereas governments are driven by national
and economic security concerns. These disparate

interests can lead to profoundly different views and perceptions about
threats, vulnerabilities, and risks, and they can affect the level of risk
each party is willing to accept and the costs each is willing to bear.
Further, the private sector may have reservations about sharing information
with law

enforcement agencies because compliance with law enforcement procedures can
be costly, or a business may not wish to report an incident that might
tarnish its image. Government entities, on the other hand, may

be reluctant to share information for national security reasons, and
declassifying and sanitizing such data takes time and could delay response.
In addition to developing trust relationships, reporting needs and
mechanisms for sharing are necessary to ensure that the right type of
information is provided and that effective and secure procedures are in

place for handling the information. This effort requires agreeing, in
advance, on the types of data to be collected and reported and the processes
to be used. 1 Critical Infrastructure Protection: Challenges to Building a
Comprehensive Strategy for Information Sharing and Cooperation (GAO/ T-
AIMD- 00- 268, July 26,

2000).

Information- sharing To improve communication and information sharing with
private- sector

Success With Private entities, the NIPC has

Sector Has Varied  attempted to establish relationships with ISACs for
individual

infrastructure sectors;  established a mutually beneficial relationship
with CERT/ CC;  expanded the FBI?s InfraGard Program to facilitate secure
information

sharing with individual entities; and  begun developing a database of key
infrastructure components, referred

to as the Key Asset Initiative. All of these efforts are in relatively early
stages of development, and their success to date has varied.

The NIPC Has Developed PDD 63 introduced the concept of establishing a
private- sector ISAC to

Two- Way Information gather and analyze industry- provided information on
threats and incidents

Sharing With One Industry and share this information with government
entities. The National Plan Sector detailed the government?s plans in this
area, on the basis of discussions

held with government and industry officials, encouraging establishment of
ISACs for major industry sectors. The National Plan noted that ISACs could
serve as a means of (1) sharing information on attempted intrusions and
attacks with industry partners and government entities and (2) obtaining
warning information from the government. Specifically, the

National Plan stated that the NIPC would use the ISACs as a means of
disseminating information to industry sectors. It also encouraged private
companies to inform federal agencies about attempted intrusions and attacks,
possibly by reporting through the ISACs. However, it stated that such
reporting was voluntary. Details of the ISACs? design and operations were to
be determined by the private sector, in consultation with and with
assistance from the federal government.

During 1999 and 2000, ISACs were established for the financial services and
telecommunications sectors. In addition, the North American Electric
Reliability Council recently formally declared itself the electric power
industry ISAC, although it had functioned in this fashion for some time.
Another ISAC, for the information technology industry, was announced by the
Secretary of Commerce on January 16, 2001, just prior to the close of our
review.

Collaboration With Electric According to NIPC and industry officials, the
?Indications, Analysis and

Power Industry Illustrates Value Warning Program? established with the North
American Electric Reliability of Public- Private Coordination

Council on behalf of the electric power industry has provided useful
information to both the NIPC and the industry sector and may prove to be a
model for future efforts in other industry sectors. The relationship between
the NIPC and the council has been successful, in part, because the electric
power industry has had a history of working directly with the FBI, so there
was an existing relationship on which to build. The council is made up of 10
regional councils from all segments of the electric industry-

investor- owned, federal, rural electric cooperatives, state/ municipal and
provincial utilities, independent power producers, and power marketers. Its
members control virtually all of the electricity supplied in the United
States, Canada, and Mexico.

In March 1999, the NIPC and the council began the Indications, Analysis, and
Warning Program with the intention of developing standard methods for
sharing and reporting information. By October 1999, they had initiated a
pilot program to test these methods and develop thresholds for incident

reporting. The council encourages the electric utility companies to
voluntarily provide the NIPC with information on unscheduled service
outages, degraded operations, and serious threats to facilities, activities,
and information systems, according to agreed- upon methods and criteria. The
agreement also stipulated requirements for the NIPC?s handling of incident
reports. For example, the NIPC is to log all reports immediately and
acknowledge receipt to the report?s originator. The NIPC then is to record
the report in an incident database and make it available to others only in
accordance with established protocols. In October and November 2000, the
NIPC held training conferences with the electric power industry

on general guidelines for electric utility companies to follow in
voluntarily reporting information to the NIPC.

According to NIPC and council officials, in addition to establishing an
information- sharing mechanism, the program has better defined the NIPC?s
information needs and provided industry members with information on
vulnerabilities and threats that they may not have otherwise obtained. For
example, in December 2000, information gathered through the electric power
industry led to detection of a potentially damaging computer exploit and
issuance of a warning to industry members and the public. Two- Way
Communication

Establishing a two- way means of communication with the Between the NIPC and
Other

telecommunications and financial services ISACs has been less successful.
ISACs Has Not Developed

Although both ISACs receive information from the NIPC, neither has

provided information in return because of reporting incompatibilities and
concerns about confidentiality. The telecommunications ISAC was officially
recognized in a January 2000

memorandum from the National Coordinator for Security, Infrastructure
Protection, and Counter- Terrorism. This ISAC is a consortium of private
carriers and federal agencies, but it is managed by the National
Communications System, an interagency entity established in the early

1960s to ensure reliable communication for the government in all situations.
According to National Communications System officials, the
telecommunications ISAC has received information from the NIPC, including
telephone calls and electronic alerts, which the ISAC, in turn, has
distributed to its membership. However, as of December 2000, these officials
said that the ISAC had not shared any incident reports with the NIPC because
ISAC members had not identified anything that was deemed important enough to
share, noting that the NIPC and the telecommunications ISAC have not agreed
to any thresholds for reporting

incidents such as those established with the electric power industry.
Furthermore, no standard thresholds have been developed between the
telecommunications ISAC and its member companies. During attempts to develop
criteria for reporting thresholds, the companies determined that it was not
currently possible due to differences in internal operational thresholds and
network monitoring software.

The Financial Services ISAC?s objective is to help ensure the viability and
continuity of the banking and finance sector from any intentional acts that
could impact critical services or the orderly functions of the economy.
Formed in October 1999, the financial services ISAC provides a data
collection and analysis center, which is managed by a private contractor

and funded by participating corporations and is structured to provide a
globally distributed analytical capability that enables broad access to
current information.

According to its operating rules established in April 2000, information on
threats and vulnerabilities from government or law enforcement sources may
be accepted by the ISAC. However, this is a one- way transfer of
information. According to ISAC documents, the ISAC is for the exclusive use
of the banking, securities, and insurance industries, and no U. S.
government entity can access its resources. As a result, the NIPC has not
benefited from information that it could have used to alert others. For

example, officials at both organizations told us that the financial services
ISAC knew about the May 2000 ILOVEYOU virus hours before the NIPC, but the
ISAC did not warn the NIPC.

The NIPC Has Begun a An additional information- sharing relationship has
been established

Mutually Beneficial between the NIPC team at the FBI?s Pittsburgh Field
Office and CERT/ CC. Relationship With CERT/ CC

Although not an industry- related ISAC, CERT/ CC, funded primarily by DOD,
is involved in gathering, analyzing, and sharing information on computer-
based vulnerabilities with private- and public- sector entities. In April
1999, the NIPC team in Pittsburgh assigned an agent to work with CERT/ CC
for 18 months. According to CERT/ CC personnel, having a law

enforcement officer work with them helped them better understand the legal
issues, including standards of evidence, involved in dealing with a computer
attack or compromise and allowed them to better advise their clients in this
regard, including collaborating on an evidence handling paper with the CERT/
CC in July 2000. In addition, they said, the NIPC team provided technical
information about a recent denial- of- service attack that helped CERT/ CC
develop a better solution.

InfraGard Program Has To facilitate information sharing directly with
individual private- sector Expanded Nationwide

entities, the NIPC adopted and expanded the InfraGard Program, which had
begun in 1996 in the FBI?s Cleveland Field Office as a pilot project.
According to InfraGard documents, the program is intended to establish a

secure mechanism for electronic two- way information sharing about intrusion
incidents and system vulnerabilities and a secure channel over which the
NIPC can disseminate analytical reports on threats to privatesector
entities. The National Plan provided more detailed objectives, stating that
the InfraGard Program would

 provide members with prompt, value- added threat advisories, alerts, and
assessments;  increase the quantity and quality of infrastructure threat
information

and incident reports provided to local FBI field offices (for coordination,
investigation, and follow up) and the NIPC (for nationallevel analysis and
warning);  increase interaction and information sharing among InfraGard

members, their local FBI field offices, and the NIPC, on infrastructure
threats, vulnerabilities, and interdependencies;

 ensure the protection of cyber and physical threat data shared among
InfraGard members, FBI field offices, and the NIPC through compliance with
proprietary, legal, and security requirements; and  provide members with a
forum for education and training on

infrastructure vulnerabilities and protection measures. By October 2000, 56
InfraGard chapters and subchapters had been established across the country
with a membership of over 277 entities. In early January 2001, NIPC
officials announced that membership had grown to 518 entities, including
representatives from the FBI, private industry, other government agencies,
state and local law enforcement, and the academic community.

InfraGard has two categories of membership- secure and nonsecure. According
to NIPC records, as of September 2000, about 78 percent of InfraGard members
had established secure memberships and could access the InfraGard Alert
Network and secure Web page. Secure memberships require a background check
verifying that applicants are not known computer hackers or criminals.
Nonsecure members do not have access to these features, but they can attend
meetings and fully participate in chapter activities. The large percentage
of secure memberships may indicate that members value InfraGard
participation. However, we did not interview

InfraGard members, so we cannot comment on their satisfaction with the
program. NIPC officials have stated publicly that the InfraGard Program
illustrates the success of their efforts in establishing trusted
relationships with private- sector entities. In addition, the officials say
the program has benefited efforts to combat computer- based attacks. For
example, on the

basis of information received from an InfraGard member, NIPC officials said
they were able to warn approximately 100 companies about a possible computer
attack that had been placed in their systems. However, agents in

one field office expressed concern that the NIPC may not be able to support
the InfraGard secure Web site with in- depth analysis, due to the
deficiencies in the NIPC?s analytical capabilities previously discussed in
chapter 2. As a result, these agents said that they were concerned that
InfraGard members? expectations may not be met.

Limited Progress in According to the National Plan, the Attorney General?s
plan, and the Identifying Key Assets

National Infrastructure Protection and Computer Intrusion Program Plan, the
Key Asset Initiative was established to identify national, regional, and

local infrastructure components, such as certain telecommunications
switching nodes, whose loss would potentially have widespread and dire
social and economic consequences. Identifying such infrastructure
components, or ?key assets,? would allow the NIPC and others involved in
critical infrastructure protection to focus their analysis, protection,
warning, and reconstitution efforts on the most important elements of the

nation?s infrastructure and facilitate recovery efforts should severe damage
occur. In addition, such information is essential to understanding the
significance of individual points of failure and assessing the potential
criticality of an attack. Without this information, organizations may
underprotect certain vital assets while overprotecting assets of lesser

importance. The NIPC and the NIPC squads at FBI field offices began
identifying key assets and developing a related database in 1998 by building
on previous FBI work, which had identified about 400 such assets. During
1999 and

2000, the NIPC hosted six training sessions, covering five industry sectors,
for Key Asset Initiative coordinators, who are typically members of NIPC
field squads and teams. According to training documents, agents in NIPC
field squads are to conduct a thorough search for key assets in their
regions for each of the eight major industry sectors. Then, the agents are
to

categorize the assets according to criteria provided. Once the list is
developed, the agents are to contact the infrastructure owners or operators
to ensure that all key assets have been identified. Lastly, they are to
assist key asset owners in the development of contingency plans, if such
plans do not exist. At the close of our review, field squads had identified
over 5,000 assets and

categorized them as being of either national, regional, or local importance,
as prescribed in NIPC training documents. However, our review of several
segments of the database and related discussions with field squad personnel
identified several indications that the field offices had not applied a
consistent methodology in identifying assets. One agent told us that he had
purposely omitted certain assets because, in his judgment, they were too
sensitive to be included. Another agent told us he had used a telephone book
as a primary source of identifying key facilities. In addition, there was
great disparity between the number of assets identified for two large
cities- over 800 assets had been identified for one city and only 34 for the
other city. NIPC officials acknowledged that a process for reviewing
database entries to ensure that FBI field offices are consistently applying
the criteria outlined in training documents was needed but had

not yet been implemented.

In addition, field squads had not yet been successful in obtaining the
agreement of industry sectors regarding the importance of the assets they
had identified because private companies have been hesitant to share
information on their most critical assets. Such validation is important
because many of the FBI agents who attempted to identify and rank

infrastructure components did not have extensive industry knowledge.
Further, according to the Attorney General?s plan, the Key Asset Initiative
was to be developed in coordination with DOD and other agencies.
Coordination among such efforts would help ensure that similar efforts
underway at the NIPC and other agencies avoid inappropriate duplication

of efforts and take advantage of the methods and findings that others have
developed.

However, such coordination had not taken place. In particular, the Key Asset
Initiative was not being coordinated with similar efforts in other agencies,
primarily because agreements on sharing sensitive information

had not been reached, as described below:  NIPC officials held discussions
with officials from Commerce?s Critical Infrastructure Assurance Office
regarding ?Project Matrix,? which is an effort led by that office to
identify critical infrastructure components and related interdependencies
affecting government operations.

However, the officials did not reach any formal agreements to share
information. An official involved with Project Matrix noted that the
information gathered through Project Matrix efforts belonged to individual
federal agencies and could not be shared without their express permission. 
NIPC and DOD officials exchanged multiple drafts of a memorandum of

understanding regarding coordination between the NIPC and DOD?s Joint
Program Office for Special Technology Countermeasures and Infrastructure
Assurance to identify infrastructure vulnerabilities that may affect DOD
bases. However, the officials had not reached any

agreements to share information as of December 2000.  Officials with the
National Communications System told us that they were approached by the NIPC
about sharing information on important

telecommunications components and facilities but declined because the
industry provided such information for internal use only and to facilitate
priority restoration during emergencies. Senior NIPC officials agreed that
much more needs to be done to validate the key asset database. They said
that significant efforts to obtain industry

support and coordinate with other federal entities were not undertaken due
to other priorities.

Information Sharing PDD 63 directs other federal agencies to share
information about threats and Coordination With and attacks with the NIPC,
where permitted by law. However, as with the

previously discussed efforts to identify key assets, the NIPC?s broader
Other Government efforts to share information and coordinate with government
entities have Entities Have Been not yielded significant results.
Specifically, federal agencies have not Limited

routinely reported incident information to the NIPC, at least in part
because OMB has directed civilian agencies to report incident information to
GSA?s Federal Computer Incident Response Capability, rather than to the
NIPC. Also, DOD and the NIPC officials say that improved informationsharing
agreements would be beneficial to their operations. Finally, the Secret
Service withdrew the detailees it had originally provided to the NIPC

because Secret Service officials felt that the Service?s personnel were not
provided appropriate responsibilities. The NIPC has been more successful in
providing training to government entities, an effort that it considers to be
an important component of its outreach efforts, and in coordinating with
foreign governments that are establishing entities similar to the NIPC.
Recent Guidance Does Not

The federal Chief Information Officers Council, which is chaired by OMB?s
Require Agencies to Report Deputy Director for Management, has issued
guidance to agencies on

to the NIPC reporting incident and vulnerability information that is
somewhat inconsistent with requirements outlined in PDD 63. Specifically,
PDD 63 states the following:

"All executive departments and agencies shall cooperate with the NIPC and
provide such assistance, information and advice that the NIPC may request,
to the extent permitted by law. All executive departments shall also share
with the NIPC information about threats and warning of attacks and about
actual attacks on critical government and private sector infrastructures, to
the extent permitted by law." In October 2000, the Chief Information
Officers Council issued a memorandum, developed in cooperation with OMB and
GSA, stating that agencies should share information on incidents and
vulnerabilities with GSA?s Federal Computer Incident Response Capability
(FedCIRC), which,

according to the National Plan, is to provide a means for federal agencies
to work together to handle security incidents, share related information,
solve common security problems, and collaborate with the NIPC and pertinent
DOD entities. While the council?s guidance did not preclude agencies from

reporting to the other organizations, it did not specifically require
agencies to report to the NIPC. Specifically it stated that agencies ?should
contact FedCIRC as soon as they identify security incidents with origins
external to the agency.? Then, depending on the nature and severity of the
incident

reported, FedCIRC would provide further guidance, including determining if
additional reporting to law enforcement or national security officials was
appropriate.

This divergence in guidance reflects unresolved differences in the
interpretation of NIPC?s role in this area. Senior NIPC officials told us
that they believe the guidance from the Chief Information Officers Council
contradicts PDD 63?s reporting requirements and that, in their view,

FedCIRC?s role as a focal point for federal reporting of computer- based
incidents and vulnerabilities is a potentially detrimental and inefficient
duplication of a portion of the NIPC?s responsibilities. These officials

would prefer that agencies report directly to the NIPC so that they can
promptly integrate such information with intelligence and law enforcement
information. NIPC officials believe that when agencies report first to

another entity, such as FedCIRC, it compromises the NIPC?s ability to
promptly issue warnings and could result in unnecessary delay and damage
should a serious incident occur. Conversely, OMB and FedCIRC officials have
contended that FedCIRC is more focused on providing assistance and

guidance to federal agencies and, therefore, is in a better position to
respond to agencies? requests for assistance; analyze the initial
information; and, if appropriate, forward it to the NIPC or others. DOD and
NIPC Information

Both NIPC and DOD officials have identified the need to improve Sharing and
Coordination

information sharing on their respective cyber- threat analysis efforts. The
Have Been Impeded by Lack

NIPC was designed to include a senior DOD manager to facilitate this of
Formal Agreements process, and DOD?s Deputy Assistant Secretary for
Information Security and Operations said that, overall, the department has a
good working relationship with the NIPC and the NIPC was very important to
its efforts in

this area. However, officials from both organizations said that a more
structured process is needed. DOD has significant efforts underway to gather
and analyze threat and vulnerability data and to detect attacks against DOD
computer systems that are either imminent or underway. For example, the
Joint Task Force for

Computer Network Defense, which is under the U. S. Space Command, monitors
incidents and potential threats and coordinates across DOD to plan and
direct actions to stop or contain damage and restore network

functionality. The task force?s specific functions include (1) synchronizing
technical, operational, and intelligence assessments of computer network
attacks; (2) assessing and reporting impacts on military operations and
capabilities; (3) coordinating the appropriate DOD actions to stop the
attack and contain damage; and (4) coordinating, as required, with other
government entities, including the NIPC, the private sector, and U. S.
allies.

Similarly, the National Security Incident Response Center, at the National
Security Agency, provides warnings of threats and expert assistance to
defense and civil agencies in isolating, containing, and resolving incidents
that threaten national security systems. The center currently manages a
database of computer incidents reported by DOD, other federal agencies, and
many foreign sources.

NIPC officials maintain that they have had numerous discussions with DOD to
develop formal requirements from defense specifying the type of information
it wanted from the NIPC. However, no procedures or mechanisms have been
developed to bring this about. An April 2000

memorandum from DOD?s Director of Infrastructure and Information Assurance
to the Assistant Secretary of Defense for Command, Control and
Communications and Intelligence recommended several actions to facilitate
information sharing and cooperation. These actions included

 establishing a more actively managed information clearinghouse and
protocol to foster reciprocal exchanges of information and fulfill the
NIPC?s information- sharing mandate;

 ensuring that sensitive information is appropriately sanitized and
handled;  ensuring that the NIPC verifies incident reports pertaining to
DOD with

DOD prior to issuing the reports; and  ensuring that the NIPC provides DOD
with more information about all

incidents, not just those directly affecting DOD, so that preventive
measures can be implemented before DOD becomes a ?victim.? To begin to
address these concerns, DOD officials told us that they planned to develop a
system for monitoring requests for information from the NIPC so that they
could better assess the success of their responses, and NIPC officials said
that they had asked DOD to develop specific information requirements.

Secret Service Not According to PDD 63, the NIPC was to include FBI and
Secret Service

Adequately Integrated Into agents as well as other investigators with
experience in computer crime

NIPC and infrastructure protection. The Secret Service is authorized by
statute

to investigate fraud related to electronic fund transfers, credit cards, and
identification documents. Accordingly, it has developed relationships with
the financial services community and technical expertise, since 1987,

through its Electronic Crimes Special Agent Program. When the NIPC was
formed in 1998, the Secretary of the Treasury requested seven positions in a
letter to the Attorney General- a request with which the former NIPC
director told us he agreed. Subsequently, two supervisory special agents
from the Secret Service were assigned to the NIPC.

However, according to a June 2000 Secret Service letter to Senator Grassley
and our interviews with Secret Service officials, contrary to Secret Service
expectations, neither of the agents was allowed to participate in
investigative activities or assigned responsibilities

commensurate with their experience or grade. NIPC and Secret Service
officials say that there were several attempts by both entities to discuss
the issues, but satisfactory agreements were not reached. As a result, the
Secret Service withdrew its detailees in October 1999, a factor that has
contributed to the NIPC?s shortage of skilled personnel. In November 2000,
the Deputy Assistant Director for Investigations at Secret Service told us
he maintains a liaison with the NIPC and that information sharing between
the two entities was improving. However, as of December 31, 2000, no Secret
Service detailees were assigned to the NIPC.

NIPC- sponsored Training PDD 63 also required the NIPC to include training
as part of its mission,

Has Served as an Additional and the National Plan noted that the NIPC was to
provide training to

Element of Its Outreach federal, state, and local officials on
infrastructure protection. In response, Efforts

the NIPC has made training a key element of its outreach and information
sharing to state and local entities. Since 1998, the NIPC has trained about
100 individuals from other federal agencies, as well as over 180 state and
local government personnel, on investigating computer crime. Table 3
provides a summary of the number of personnel trained from May 1998 through
August 2000.

Table 3: Personnel Trained by the NIPC From May 1998 Through August 2000
Number of personnel who attended training

FY 1998 FY 2000

(May 1998 - (Oct. 1999 Aug.

Entities Oct . 1998) FY 1999 2000)

FBI 250 339 373 Other federal agencies 10 31 60 State and local 10 27 150
International 2 0 12

Total 272 397 595

Source: NIPC.

The NIPC Has Undertaken The NIPC has worked on a range of international
initiatives designed to International Initiatives

foster better information sharing and communication across national borders.
Since its founding in 1998, the NIPC has advised representatives from
Canada, Germany, Japan, Sweden, and the United Kingdom, all of which are in
the process of forming interagency entities like the NIPC.

Also, in October 2000, the NIPC and the United Kingdom?s National
Infrastructure Security Coordination Center formed an operational subgroup
to address (1) connectivity between the NIPC and the center, (2)
coordination of outreach and information- sharing activities, and (3) ways
to improve and accelerate the flow of information between the two entities
and their respective partners.

Another international initiative that the NIPC has been involved in is a
hightech crime subgroup sponsored by eight major industrialized countries,
including Canada, France, Germany, Italy, Japan, the United Kingdom, the

United States, and Russia, collectively referred to as the G- 8. An NIPC
representative serves as a member of the U. S. delegation to the subgroup,
which has been considering several issues concerning international cyber
crime investigations, including the establishment of a 24- hour- a- day,
hightech crime network; international training conferences; reviews of legal
systems in G- 8 countries; and the development of principles on transborder
access to stored computer data.

Finally, the NIPC has provided training to investigators from several
nations through international law enforcement academies in Hungary and
Thailand. In addition, a small number of select international investigators
have received training in NIPC- sponsored classes in the United States.

During 2000, the NIPC records show that it participated in about 56
international events and provided briefings to visitors from 23 countries.

Conclusions The NIPC?s information- sharing relationships are still evolving
and will probably have limited effectiveness until reporting procedures and
thresholds are defined and trust relationships are established. While a
growing number of entities have entered into information- sharing agreements
with the NIPC and the FBI, two- way information- sharing partnerships have
not developed between the NIPC and certain industry ISACs. This lack of
cooperation impedes efforts to identify key assets that merit special
protective efforts and identify and address vulnerabilities,

and it increases the risk that a broad computer- based attack would not be
detected or mitigated until significant damage had occurred. In addition,
much work remains to develop cooperative relationships among government
entities, including civilian agencies, DOD, and law enforcement entities, to
ensure that similar or related critical infrastructure protection efforts
are coordinated and that the expertise of agency

personnel is used effectively. Recommendations for

To develop the information- sharing goals identified in PDD 63 and related
Executive Action

plans, we recommend that the Assistant to the President for National
Security Affairs (1) direct federal agencies and encourage the private
sector to better define the types of information that are necessary and
appropriate to exchange in order to combat computer- based attacks and
procedures for performing such exchanges; (2) initiate development of a
strategy for identifying assets of national significance that includes
coordinating efforts already underway, such as those at DOD and Commerce;
and (3) resolve discrepancies between PDD 63 requirements and guidance
provided by the federal Chief Information Officers Council regarding
computer incident reporting by federal agencies.

We further recommend that the Attorney General direct the FBI Director to
direct the NIPC Director to (1) formalize relationships between the NIPC and
other federal entities, including DOD and the Secret Service, and

private- sector ISACs so that a clear understanding of what is expected from
the respective organizations exists; (2) develop a plan to foster the two-
way exchange of information between the NIPC and the ISACs; and (3) ensure
that the Key Asset Initiative is integrated with other similar federal
activities.

Agency Comments and In comments pertaining to this chapter, the Director of
the NIPC

Our Evaluation recommended that our report more fully discuss the underlying
causes that have led some in the private sector to offer limited or uneven
cooperation with the government regarding the sharing of information related
to

infrastructure protection. The Director noted that each component in
infrastructure protection operates under internal and external constraints
on information sharing, which are based on important considerations in each
component?s mission. In this regard, he stated that Justice and the

NIPC have worked, and will continue to work, to develop effective protocols
for information sharing within the bounds of each component?s legal and
policy structures and provide a level of certainty that shared information
will be appropriately protected. He asserted that, through

such protocols, information necessary for protecting infrastructures can be
effectively shared on a timely basis. He further cited several reasons why
some private- sector organizations have been reluctant to share information

with the government, including the NIPC. The reasons cited include (1) a
lack of understanding or confidence in the exceptions found in the Freedom
of Information Act, (2) concerns about whether Justice would pursue
prosecutions at the expense of private- sector business interests, and (3)
concerns about disclosing proprietary information to an entity

beyond their control. The Director said that, to address these concerns, the
NIPC has reached out to communities across the nation to build trust and
educate the public on the legal and security aspects of information sharing
and protection, citing the InfraGard Program and the NIPC?s successful
information- sharing relationship with the electric power ISAC. In addition,
he cited two specific instances in which NIPC advisories were coordinated

in advance with private- sector entities, including three ISACs, as evidence
of the growing cooperative arrangement between the NIPC and the private
sector. The Director did not specifically address our recommendations to the
NIPC regarding the need to formalize relationships with other federal
entities or ensure that the Key Asset Initiative is integrated with other
similar federal activities. The NIPC?s comments reiterate many of the points
made in our report regarding the challenges associated with building
productive informationsharing relationships between private and public-
sector entities, and they provide some additional specific detail. We agree
that the underlying factors that inhibit information sharing are important,
and our report cites our July 2000 testimony, which provides a much more
detailed discussion

of the related challenges. We also agree that the NIPC has taken a number of
steps to address these concerns through the InfraGard Program and by

establishing cooperative relationships with the electric power ISAC and
others. It is important that these efforts continue. In addition, as our
report states, it is important that the NIPC strive for improved cooperative
relationships with other federal entities involved in critical
infrastructure protection.

In commenting on a draft of this report, the Special Assistant to the
President and Senior Director for Legislative Affairs at the National
Security Council said that the administration will consider our
recommendations as it reviews federal cyber activities to determine how the
critical infrastructure protection function should be organized. The
comments did not specifically address our recommendations regarding (1)
better defining needed information for combating cyber attacks, (2)

developing a strategy for identifying assets of national significance, and
(3) resolving discrepancies in guidance on computer incident reporting by
federal agencies.

The comments from the NIPC and the National Security Council are printed in
full in appendixes I and II, respectively.

Funding Used For a Variety of NIPC- related

Chapt er 5

Activities Following congressional direction and on the basis of
requirements estimated by NIPC officials, the FBI reportedly provided the
NIPC with about $32 million and about $28 million for fiscal years 1999 and
2000, respectively. In addition, the FBI provided the NIPC with
administrative services, including budgeting, accounting, training,
telecommunications, and facilities, at no cost to the NIPC. Other government
agencies provided the NIPC with additional resources in the form of at least
39 detailees over fiscal years 1999 and 2000. The detailees filled a variety
of NIPC positions on a nonreimbursable basis. On the basis of our analysis
of information provided to us by the FBI Finance Division and the NIPC, the
NIPC obligated about 84 percent of its

available fiscal years 1999 and 2000 funds. The rest of the available funds
that the NIPC did not obligate were ?no- year? funds that remained available
for fiscal year 2001. The NIPC used the funds to support its analysis and

warning activities, investigation of computer crime, and outreach and
information sharing with government and private- sector entities.

Most of the funding was reportedly used for activities performed by NIPC
staff located at FBI headquarters in Washington, D. C. On the basis of the
documents provided, the NIPC used about 16 percent of its fiscal years 1999
and 2000 funds to pay for training, travel, and information technology

for NIPC field squads and teams located in FBI field offices. These funds
were in addition to the salaries and expense amounts provided by the FBI
field offices to the NIPC field squads and teams. According to FBI
officials, the amounts reportedly used to support the NIPC field squads and
teams by their respective FBI field offices could not be readily determined
because those amounts are not accounted for separately from other FBI field

operations. In addition, the salary amounts for the FBI agents and support
staff assigned to the NIPC were estimated because the agents? salaries are
not accounted for separately from other FBI operations.

The FBI Provided Justice appropriations laws for fiscal years 1999 and 2000
did not specify Funds to the NIPC on

funding or provide specific direction for the NIPC; however, funding
guidance was provided in congressional conference reports related to the
Basis of Justice?s fiscal years 1999 and 2000 appropriations. 1 The sources
and Congressional amounts specified in this funding guidance are identified
in tables 4 and 5. Direction and NIPC

Requirements

Table 4: Fiscal Year 1999 NIPC Funding Specified in Congressional Conference
Report Source of funding Amount specified

FBI salaries and expenses $33, 542, 000 Department of Justice
Counterterrorism Fund 10, 000, 000 Department of Justice Working Capital
Fund, if available, for an

4,250, 000 early warning system Tot al $47,792, 000

The conference report earmarked $10.1 million from the fiscal year 1999 FBI
salaries and expenses appropriation for the following purposes:

 $8. 7 million for positions to establish four additional Computer
Intrusion Threat Assessment field squads, which became NIPC field squads; 
$0.5 million for equipment for the new field squads;  $0. 4 million for
additional positions for the NIPC?s Watch and Warning

Analysis Unit; and  $0. 5 million for training programs related to computer
crime detection.

1 House of Representatives, Conference Report 825, 105 th Congress, Second
Session 1998, Making Omnibus Consolidated and Emergency Supplemental
Appropriations of Fiscal Year 1999 and House of Representatives, Conference
Report 479, 106 th Congress, First Session 1999, Making Appropriations for
the Government of the District of Columbia and Other Activities Chargeable
in Whole or in part Against Revenues of Said District for the Fiscal Year
Ending September 30, 2000, and for Other Purposes.

Table 5: Fiscal Year 2000 NIPC Funding Specified in Congressional Conference
Report Source of funding Amounts specified

FBI salaries and expenses: National Infrastructure Protection $18,596, 000
Center/ Computer Intrusion Estimated carryover available from fiscal years
1998 and 1999 2,069, 436

no- year funds from the Violent Crime Reduction Trust Fund, the Department
of Justice Counterterrorism Fund, and the Department of Justice Working
Capital Fund

Tot al $20,665, 436

The fiscal year 2000 conference report noted that the new funding combined
with the estimated carryover from fiscal years 1998 and 1999 would provide
the NIPC with ?approximately the same level of funding

available in fiscal year 1999, adjusted for some nonrecurring requirements.?
According to FBI officials, the carryover discussed in the report was an
estimated amount provided to congressional appropriations staff and was not
meant to represent the final amount available because, at the time of
congressional conferences, the fiscal year- end amount of carryover was not
known. In addition, the conference report designated $1,250,000 from the
fiscal year 2000 FBI salaries and expenses appropriation for the
establishment of a ?cybercrime? partnership with the Thayer School of
Engineering at Dartmouth College.

On the basis of subsequent discussions with appropriations committee staffs,
2 the FBI ultimately provided funding to the NIPC that differed from the
amounts specified in the conference reports. According to FBI Finance
Division officials, the funding amounts agreed to and provided by the FBI
were based on the NIPC?s estimated requirements, as established in the

President?s budget requests. Tables 6 and 7 summarize the sources and
amounts of NIPC funding for fiscal years 1999 and 2000. In fiscal year 1999,
the FBI provided the NIPC with $15.9 million less than specified in the
conference report and, in fiscal year 2000, $7.3 million more than specified

in the conference report. 2 According to FBI officials, discussions
regarding fiscal years 1999 and 2000 NIPC funding were held with staff from
the Subcommittee on Commerce, Justice, State and the Judiciary, Senate
Committee on Appropriations, and the Subcommittee on Commerce, Justice,
State and the Judiciary, House Committee on Appropriations.

Table 6: Fiscal Year 1999 Funding Provided to the NIPC From the FBI Amounts
Source of funds available

Fiscal year 1999 funds

Salaries and expenses $9, 435, 000

No- year funds

Violent Crime Reduction Trust Fund 5,900, 000

Violent Crime Reduction Trust Fund carryover From fiscal year 1998 2,317,
442

Department of Justice Counterterrorism Fund 10, 000, 000

Department of Justice Working Capital Fund 4,250, 000

Tot al $31,902, 442 Table 7: Fiscal Year 2000 Funding Provided to the NIPC
From the FBI

Amounts Source of funds available

Fiscal year 2000 funds

Salaries and expenses $10, 071, 000 Estimated amount from Department of
Justice reprogrammed and

771, 968 reallocated for a fiscal year 2000 FBI compensation and benefits
shortfall a

No- year funds

Violent Crime Reduction Trust Fund, including $1.25 million for Thayer
School of Engineering

9,150, 000 Fiscal year 1999 carryover

666, 608 Fiscal year 1998 carryover

142, 769 Department of Justice Counterterrorism Fund Carryover

5,272, 023 Department of Justice Working Capital Fund Carryover

1,930, 624

Tot al $28,004, 992

a According to FBI officials, the FBI received $68.4 million in reprogrammed
and reallocated funds for fiscal year 2000 to meet a compensation and
benefits shortfall.

In addition to the funding provided from the FBI, the NIPC received
resources during fiscal years 1999 and 2000 in the form of administrative
services from other FBI divisions and detailees from other government
agencies. The FBI provided to the NIPC budgeting, accounting, training,
telecommunications, and facilities services, which are typically provided to
all FBI operational organizations, including the Counterterrorism Division,

at no cost to the NIPC. For example, the FBI Finance Division provided
support for NIPC?s budget formulation and execution and maintained

accounting records, and the FBI?s National Security Division provided
requisition processing and document maintenance. Also, some of the training
and related travel expenses for NIPC personnel were covered by the FBI?s
Quantico training facility without reimbursement. In addition, the
Information Resources Division provided the NIPC with basic
telecommunications services at no cost to the NIPC, but the NIPC had to pay
for specialized telecommunications requirements, which are reflected in
table 8. Further, the FBI provided the NIPC with the facilities occupied

in the FBI building without reimbursement. At least 39 detailees also served
at the NIPC for varying periods. Although information regarding departure
dates for some detailees was incomplete, at least 19 of the 39 people served
for less than 12 months. All detailees were provided on a nonreimbursable
basis.

Funds Primarily Used On the basis of our analysis of documents provided by
the NIPC and the

to Support The NIPC FBI Finance Division, about 84 percent of the funds that
the NIPC obligated

in fiscal years 1999 and 2000 were for activities conducted at the NIPC in
Washington, D. C. The NIPC used the rest of the funds it obligated to
support the NIPC field squads and other NIPC teams located in FBI field
offices. Table 8 details the amounts obligated for the NIPC in fiscal years
1999 and 2000. FBI Finance Division and NIPC officials developed all of the
amounts shown on the basis of information extracted from FBI accounting
records. Amounts for salaries, including compensation and benefits, were
estimated because the FBI?s accounting records did not segregate funds
applicable to the FBI agents and support personnel assigned to the NIPC from
other FBI obligations.

For fiscal years 1999 and 2000, combined, the NIPC obligated funds for the
following key items:  Salaries for FBI personnel assigned to the NIPC (32
agents and about 60 support personnel) ($ 14. 9 million).  Information
technology, including hardware and software, for the NIPC

($ 7.1 million) and the field squads and teams ($ 4.8 million).  Contracts
($ 12 million) that supported  a foreign counterintelligence investigation;
 the NIPC?s emergency law enforcement sector responsibilities,

including providing case summaries and an emergency law enforcement services
sector draft plan;  development of InfraGard Program information;

 development of periodic articles;  development of training courses,
exercises, and software tools;  development of an incident analysis
database;  development of an early warning system that is intended to link
numerous sources of electronic information to facilitate searches and
accelerate investigations;

 research of existing and future Internet topology, including development
of related tools to support investigations; and  a ?help desk? function for
the NIPC.  NIPC field squad training, including related travel, for Key
Asset Initiative conferences, technical courses, and NIPC- related courses
at the FBI?s Quantico, VA, training facility ($ 3.3 million).

Table 8: Amounts Obligated by the NIPC During Fiscal Years 1999 and 2000
Obligated amounts

FY 1999 FY 2000 Single- year funds obligated

Salaries 6,614, 888 8,271, 923 Expenses

Other tuition and training 48, 426 36, 789 Advisory and assistance 692, 629
513, 425 Routine travel 554, 361 540, 414 Regional conference travel 68, 048
456, 631 Miscellaneous other services 292, 406 40, 256 Routine supplies 84,
813 79, 976 NIPC equipment 751, 700 325, 554 Telecommunications 80, 184 485,
000 Conference room space rental 3,650 - Confidential expenditure 150, 000
93, 000 Compensation and benefits (NIPC overtime) 35, 800 -

Subtotal 2,762, 017 2,571, 045 Tot al 9, 376, 905 10, 842, 968 No- year
funds obligated Violent crime reduction trust fund obligations

Routine travel 78, 039 51, 548 Regional conference travel 358, 018 59, 914
Temporary duty travel 120, 968 19, 531

(Continued From Previous Page)

Obligated amounts FY 1999 FY 2000

Consulting services 1,611, 355 4,453, 427 Non- GSA building maintenance
1,300, 000 - Office equipment 1,765, 012 3,550, 429 Other automated data
processing services -- 223, 882 Commercial training -- 92, 588 Other
tuition/ training services -- 60, 000 Late payment penalty -- 25, 771
Subtotal 5,233, 392 8,537, 090

Fiscal year 1998 carryover Routine travel 356, 323 42, 923 Regional
conference travel 5,788 - Temporary duty travel 57, 397 - Other tuition and
training 123, 468 - Consulting services 187, 596 - Office equipment 1,365,
820 99, 846

Subtotal 2, 096, 392 142, 769 Fiscal year 1999 carryover Routine travel --
181, 963

Regional conference travel -- 80, 101 Temporary duty travel -- 27, 982
Consulting services -- 18, 029 Other automated data processing services --
46, 441 Office equipment -- 65, 604

Subtotal -- 420, 120 Tot al 7,329, 784 9,099, 979 Counterterrorism fund
obligations

Routine travel -- 3, 241 Miscellaneous telecommunications -- 43, 115 Other
tuition and educational training -- 976, 180 Consulting services 2, 884, 878
831, 365 Non- GSA building maintenance 398, 349 - Miscellaneous services
380, 886 - Automated data processing services 621, 088 - Supplies 83, 541
31, 123 Intelligent workstations -- 53, 975 Office equipment 358, 500 2,
966, 012

(Continued From Previous Page)

Obligated amounts FY 1999 FY 2000

Late payment penalty 735 6, 532

Tot al 4,727, 977 4,911, 543 Department of Justice working capital fund
obligations

Rental of miscellaneous equipment 10, 022 - Automated data processing
services 1, 414, 055 682, 522 Consulting services 185, 560 1, 221, 670
Office equipment 708, 141 21, 977 Miscellaneous services 1 - Late payment
penalty 1,597 -

Tot al 2,319, 376 1,926, 169 Total no- year funds obligated 14, 377, 137 15,
937, 691 Total obligated amount for the NIPC 23, 754, 042 26, 780, 659

Conclusions From the information provided by the NIPC and the FBI Finance
Division, the FBI appears to be funding the NIPC on the basis of the
congressional direction provided in the relevant conference reports and
subsequent

discussions with appropriations committee staffs. The NIPC used those funds
primarily to support activities performed by NIPC staff located at FBI
headquarters in Washington, D. C. About 16 percent of the NIPC?s available
funding was used to support the NIPC squads and teams at FBI field

offices. We are making no recommendations regarding the NIPC?s use of funds.

Agency Comments In commenting on a draft of this report, the Director of the
NIPC noted that our report stated that the FBI appears to be funding the
NIPC on the basis of congressional direction. Neither the NIPC comments nor
those of the Special Assistant to the President provided any additional
references to this chapter.

Appendi xes Comments From the National Infrastructure

Appendi x I Protection Center

Comments From the National Security

Appendi x II Council

(511997) Lett er

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GAO United States General Accounting Office

Page 1 GAO- 01- 323 Critical Infrastructure Protection

Contents

Contents Page 2 GAO- 01- 323 Critical Infrastructure Protection

Contents Page 3 GAO- 01- 323 Critical Infrastructure Protection

Page 4 GAO- 01- 323 Critical Infrastructure Protection

United States General Accounting Office Washington, D. C. 20548

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Executive Summary Page 9 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 10 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 11 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 12 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 13 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 14 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 15 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 16 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 17 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 18 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 19 GAO- 01- 323 Critical Infrastructure Protection

Executive Summary Page 20 GAO- 01- 323 Critical Infrastructure Protection

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Chapter 1

Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 2

Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 2 Multiple Factors Limit Progress in Developing National Analysis
and Warning Capabilities

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Chapter 3

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 61 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 62 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 63 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 64 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 65 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 66 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 67 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 68 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 69 GAO- 01- 323 Critical Infrastructure
Protection

Chapter 3 The NIPC Has Provided Valuable Support and Coordination in
Improving Investigation and

Response Capabilities Page 70 GAO- 01- 323 Critical Infrastructure
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Chapter 4

Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Chapter 4 Progress In Information Sharing And Outreach Has Been Mixed

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Page 88 GAO- 01- 323 Critical Infrastructure Protection

Chapter 5

Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Chapter 5 Funding Used For a Variety of NIPC- related Activities

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Appendix I

Appendix I Comments From the National Infrastructure Protection Center

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Appendix I Comments From the National Infrastructure Protection Center

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Appendix I Comments From the National Infrastructure Protection Center

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Appendix I Comments From the National Infrastructure Protection Center

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Appendix I Comments From the National Infrastructure Protection Center

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Page 102 GAO- 01- 323 Critical Infrastructure Protection

Appendix II

Appendix II Comments From the National Security Council

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United States General Accounting Office Washington, D. C. 20548- 0001

Official Business Penalty for Private Use $300

Address Correction Requested Presorted Standard

Postage & Fees Paid GAO Permit No. GI00
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