Progress in Developing the National Asset Database

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$J1L(lO~ \~ ~~ - Center for Investigative Reporting$

Management Comments and OIG AnalysisDHS’ Office of Preparedness commented on our draft report (a copy of itsresponse in its entirety is recorded in Appendix B) and we incorporatedseveral specific comments by DHS into this report. Additional analysis ofDHS’ comments and responses to the recommendations follows. Based onthe response and additional discussions with NADB program officials, wemodified each of our recommendations.General CommentsPreparedness was concerned that the report did not accurately reflect thenature of criticality in the NADB, noting that the NADB is an inventory ofassets across the nation to then be filtered to develop appropriate critical assetlists. It believes that criticality is not an important part of the initial inventory.We understand the purpose of the inventory, but believe that considering therelevance of questionable data is worthwhile. We concur that criticality maybe conditional, reflecting time or other concerns, and the NADB shouldinclude more than just assets of obvious criticality. For example,Preparedness suggested that schools are essential not for infrastructureprotection, but for additional uses in operational support. While suchambitious uses of the NADB may be worthwhile, they should not distractfrom the stated mission of the NADB in supporting the protection of criticalinfrastructure. It should not be a reason to reject the concept of criticality, butrather a reason to refine the definitions of criticality applied. We havemodified some of the language in the report to clarify the role of the NADB inthe process of infrastructure protection.Preparedness was also concerned that issues of insufficient staffing andfunding were underrepresented in the report. We sought, and IP provided,some details regarding the NADB program budget. However, at the time ofour report, we did not have sufficient information to draw conclusionsregarding program needs. In its action plan to address Recommendation #4,IP should indicate whether funding shortfalls would impact its ability to meetcertain milestones.Specific Comment #8Preparedness sought to clarify the role of the NADB as an asset inventory inthe process of developing situational prioritized lists. Their response statedProgress in Developing the National Asset Database22
that not only does the department not have one definitive prioritized list, butalso that such a list is “neither possible nor useful….” Rather, Preparednesssees the NADB’s mission as supporting “a variety of asset groups forprogrammatic focus or to answer specific questions.”We recognize the distinction between the NADB as an inventory and themultiple prioritized lists of CI/KR that are created using the inventory. Weclarified this distinction in our final report. However, we maintain that acomprehensive picture of CI/KR across the entire nation’s infrastructure isdesired. The NIPP lists the “[p]rioritization of assets and systems acrosssectors and jurisdictions…” 43 as one of the stated goals of the next generationNADB. While the NADB is used to inform programmatic analyses, amaturing NADB is also essential to the development of a comprehensivepicture of the nation’s CI/KR.While risk-based prioritization currently supports specific programs andsector-specific goals, it also has value in informing overarching budgetpriorities across CI/KR sectors. That said, we are not entirely clear as to whatthe “comprehensive picture” 44 will look like, and how DHS will interpret it tomake funding decisions.Recommendation #1: Define, and systematically examine, out-of-place or“extremely insignificant” assets, and determine which of those assetsshould remain in the NADB. Consider redesignating low value assetsremaining in the NADB.Preparedness perceived our original recommendation as misguided,representing a misunderstanding of the nature of the NADB’s role as aninventory rather than as a critical list.Based on Preparedness’ response and discussions with program officials, wemodified this recommendation. We believe that the presence of out-of-placeassets still warrants management’s attention. Over the development of thisinventory, DHS has deferred to the judgment of the state, locality, or agencyabout which assets they should submit for the purposes of infrastructureprotection, but there is evidence that these entities submitted assets for reasonsother than state or local criticality assessments. This has led to out-of-placeassets that should never have been included, and will never be used to inform43 Draft NIPP, p. 8244 IbidProgress in Developing the National Asset Database23
Page 1 and 2: DRAFTDEPARTMENT OF HOMELAND SECURIT
Page 3 and 4: ContentsExecutive Summary..........
Page 5 and 6: Executive SummaryOn December 17, 20
Page 7 and 8: such as prominent national, state,
Page 9 and 10: Chart 1: NADB Totals by SectorAgric
Page 11 and 12: Chart 2: NADB Totals by Stages of D
Page 13 and 14: IP officials view the new taxonomy
Page 15 and 16: assets (such as schools) should be
Page 17 and 18: all but Indiana) and identified sev
Page 19 and 20: mortuaries, 571 nursing homes, and
Page 21 and 22: capability to be queried in a varie
Page 23 and 24: eports and reluctance of the privat
Page 25: development in other sectors, and a
Page 29 and 30: Recommendation #3: For ongoing and
Page 31 and 32: Appendix APurpose, Scope, and Metho
Page 33 and 34: Appendix BPreparedness Response to
Page 39 and 40: Appendix CRoles/Responsibilities wi
Page 45 and 46: Appendix DCritical Infrastructure a
Page 47 and 48: Appendix EGuidelines for Identifyin
Page 49 and 50: Appendix EGuidelines for Identifyin
Page 51 and 52: Appendix FCritical Infrastructure/K
Page 53 and 54: Appendix HReport DistributionDepart

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