New draft of cyber response plan nearly ready for release

After months of debate and deliberation, the Department of Homeland Security is putting the final touches on a revised plan that is designed to expand on Presidential Policy Directive 41.

Shutterstock image (by Pavel Ignatov): Alert icon.

The Department of Homeland Security is nearly ready to release a draft of the National Cyber Incident Response Plan that has been anticipated and debated for months.

The latest version, which was shared with stakeholders for final comment, moves the NCIRP from the interim draft status under which it's languished since 2009 and inches it closer to a final plan. FCW obtained a copy of that stakeholder release, which runs just over 50 pages with appendices.

The draft NCIRP follows the July release of Presidential Policy Directive 41, which outlines the roles and responsibilities of government agencies in responding to cyber incidents. The NCIRP is designed to fill in details PPD-41 left unaddressed, especially regarding private-sector responsibilities.

"This update to the NCIRP focuses on discrete, critical content revisions," the introduction to the document states. "While the focus of the NCIRP is on cyber incident response efforts, there is a broader architecture outlined within the National Preparedness System that establishes how the whole community prevents, protects against, mitigates, responds to and recovers from all threats and hazards."

The plan's stated purpose is "to provide guidance to enable a coordinated whole-of-nation approach to response activities and coordination with stakeholders during a significant cyber incident impacting critical infrastructure."

Furthermore, "recognizing the shared responsibility for cybersecurity, response activities in the NCIRP are undertaken through four concurrent lines of effort: threat response, asset response, intelligence support and related activities, and the affected entity's response efforts," the document states.

One area not addressed in detail in PPD-41 is the role of the private sector in the response to a significant cyber incident.

"Private-sector cybersecurity practitioners and providers [that] offer critical services -- such as managed security services, indications and warning, cybersecurity assessment, and incident response -- may also possess information concerning malicious cyber activity that is important for enabling threat response activities," the draft states.

It goes on to say that "private entities that have a mandatory reporting requirement should assure that they report incidents that meet the required reporting thresholds even if they may otherwise mitigate the event. In most cases, these incidents are considered routine and are mitigated by the company using internal resources or with the assistance of contracted services providers."

The draft also outlines a series of cross-cutting core capabilities and threat response, asset response and intelligence support capabilities. And it highlights coordinating structures and operational response protocols.

"DHS is facilitating efforts to identify procedures for creating and accrediting Information Sharing and Analysis Organizations to allow for groups of stakeholders to create information-sharing groups based on affinity among members (e.g., geography, industry or community segment, or threat exposure) that could provide a more formalized structure for information sharing and the provision of technical assistance," the draft states.

PPD-41 identified federal agencies that would take the lead in responding to cyber incidents that have health, safety or national security implications. Those agencies will coordinate their activities through Cyber Unified Coordination Groups, and the NCIRP provides greater detail on the members and roles of those groups.

"To the maximum extent allowed by applicable law, Cyber UCGs will share cyberthreat information developed during incident response with other stakeholders as quickly, openly and regularly as possible to ensure protective measures can be applied with all applicable stakeholders," the document states. "This sharing may at times be constrained by law, regulation, the interests of the affected entity, classification or security requirements, or other operational considerations."

An industry expert with intimate knowledge of the draft process said it is a significant step forward from PPD-41. A great deal of time was spent determining what capabilities must be in place and who can best provide those capabilities, the expert said -- whether that is the Federal Emergency Management Agency, the National Guard or the private sector.

The source told FCW the draft plan takes into account the fact that there are industry capabilities that the government simply doesn't have, and the appropriate industry representatives must be identified and on standby for possible response. The source added that DHS took seriously the concerns and input of industry, and although not everyone is happy, the private sector generally views the draft in a positive light.

However, as with PPD-41, experts inside and outside government say that until the system is activated in response to a cyber incident, it is impossible to tell whether the lines of coordination and communication have been properly connected and will function as anticipated.

The draft will soon enter a 30-day comment phase. The goal is to have a finalized NCIRP before the start of the next presidential administration.

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