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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Oversight, Investigations, and Management, 
Committee on Homeland Security, House of Representatives: 

For Release on Delivery: 
Expected at 10:00 a.m. CDT:
Wednesday, August 24, 2011: 

Maritime Security: 

Progress Made, but Further Actions Needed to Secure the Maritime 
Energy Supply: 

Statement of Stephen L. Caldwell: 
Director: 
Homeland Security and Justice Issues: 

GAO-11-883T: 

GAO Highlights: 

Highlights of GAO-11-883T, a testimony before the Subcommittee on 
Oversight, Investigations, and Management; Committee on Homeland 
Security; House of Representatives. 

Why GAO Did This Study: 

The nation’s economy and security are heavily dependent on oil, 
natural gas, and other energy commodities. Al-Qa’ida and other groups 
with malevolent intent have targeted energy tankers and offshore 
energy infrastructure because of their importance to the nation’s 
economy and national security. The U.S. Coast Guard—a component of the 
Department of Homeland Security (DHS)—is the lead federal agency for 
maritime security, including the security of energy tankers and 
offshore energy infrastructure. The Federal Bureau of Investigation 
(FBI) also has responsibilities for preventing and responding to 
terrorist incidents. This testimony discusses the extent to which (1) 
the Coast Guard and the FBI have taken actions to address GAO’s prior 
recommendations to prevent and respond to a terrorist incident 
involving energy tankers and (2) the Coast Guard has taken actions to 
assess the security risks to offshore energy infrastructure and 
related challenges. This testimony is based on products issued from 
December 2007 through March 2011 and recently completed work on the 
Coast Guard’s actions to assess security risks. GAO reviewed documents 
from the Coast Guard’s risk model and relevant laws, regulations, 
policies, and procedures; and interviewed Coast Guard officials. 

What GAO Found: 

The Coast Guard and the FBI have made progress implementing prior 
recommendations GAO made to enhance energy tanker security. In 2007, 
GAO made five recommendations to address challenges in ensuring the 
effectiveness of federal agencies’ actions to protect energy tankers 
and implement response plans. The Coast Guard and the FBI have 
implemented two recommendations, specifically: (1) the Coast Guard, in 
coordination with U.S. Customs and Border Protection, developed 
protocols for facilitating the recovery and resumption of trade 
following a disruption to the maritime transportation system, and (2) 
the Coast Guard and the FBI participated in local port exercises that 
executed multiple response plans simultaneously. The Coast Guard has 
made progress on a third recommendation through work on a national 
strategy for the security of certain dangerous cargoes. It also plans 
to develop a resource allocation plan, starting in April 2012, which 
may help address the need to balance security responsibilities. 
However, the Coast Guard and the FBI have not yet taken action on a 
fourth recommendation to develop an operational plan to integrate the 
national spill and terrorism response plans. According to DHS, it 
plans to revise the National Response Framework, but no decision has 
been made regarding whether the separate response plans will be 
integrated. Also, DHS has not yet taken action on the final 
recommendation to develop explicit performance measures for emergency 
response capabilities and use them in risk-based analyses to set 
priorities for acquiring needed response resources. According to DHS, 
it is revising its emergency response grant programs, but does not 
have specific plans to develop performance measures as part of this 
effort. 

The Coast Guard has taken actions to assess the security risks to 
offshore energy infrastructure, which includes Outer Continental Shelf 
(OCS) facilities (facilities that are involved in producing oil or 
natural gas) and deepwater ports (facilities used to transfer oil and 
natural gas from tankers to shore), but improvements are needed. The 
Coast Guard has used its Maritime Security Risk Analysis Model (MSRAM) 
to examine the security risks to OCS facilities and deepwater ports. 
To do so, the Coast Guard has coordinated with the intelligence 
community and stakeholders, such as the Department of the Interior’s 
Bureau of Ocean Energy Management, Regulation and Enforcement. 
However, the Coast Guard faces complex and technical challenges in 
assessing risks. For example, the Coast Guard does not have data on 
the ability of an OCS facility to withstand an attack. The Coast Guard 
generally recognizes these challenges and has actions underway to 
study or address them. Further, GAO determined that as of May 2011, 
the Coast Guard had not assessed security risks for 12 of the 50 
security-regulated OCS facilities that are to be subjected to such 
assessments. Coast Guard officials later determined that they needed 
to add these OCS facilities to MSRAM for assessment and have completed 
the required assessments. However, while the list of security-
regulated facilities may change each year based on factors such as 
production volume, the Coast Guard’s current policies and procedures 
do not call for Coast Guard officials to provide an annual updated 
list of regulated OCS facilities to MSRAM analysts. Given the 
continuing threat to such offshore facilities, revising its procedures 
could help ensure that the Coast Guard carries out its risk assessment 
requirements for security-regulated OCS facilities. 

What GAO Recommends: 

GAO is recommending that the Coast Guard revise policies and 
procedures to ensure its analysts receive the annual updated list of 
regulated offshore energy facilities to ensure risk assessments are 
conducted on those facilities. The Coast Guard concurred with this 
recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-11-883T] or key 
components. For more information, contact Stephen Caldwell at (202) 
512-9610 or caldwells@gao.gov. 

[End of section] 

Chairman McCaul, Ranking Member Keating, and Members of the 
Subcommittee: 

[End of section] 

I am pleased to be here today to discuss federal efforts to ensure the 
security of energy tankers and the offshore energy infrastructure that 
produces, transports, or receives oil and natural gas. The nation's 
economy and security are heavily dependent on oil, natural gas, and 
other energy commodities. Further, it is fitting that today's hearing 
is in Houston because the city and the surrounding area play a central 
role in the maritime energy sector. Houston is home to hundreds of 
energy companies and many of these companies are involved in exploring 
for and producing oil and natural gas in the Gulf of Mexico and 
transporting it from sea to shore. In addition, energy tankers sail 
through the Houston Ship Channel, and major facilities for refining 
oil are located along or near the channel. 

Al-Qa'ida and other groups with malevolent intent continue to target 
energy tankers and offshore energy infrastructure because of their 
importance to the nation's economy and national security. In May 2011, 
the Department of Homeland Security (DHS) issued a press statement 
that intelligence information showed that throughout 2010 there was 
continuing interest by members of al-Qa'ida in targeting oil tankers 
and commercial oil infrastructure at sea. While a terrorist attack on 
energy tankers or offshore energy infrastructure has not occurred in 
the United States, other countries have experienced such attacks. 

Additionally, while it was not the result of an attack, the Deepwater 
Horizon explosion in April 2010 showed that the consequences of an 
incident on offshore energy infrastructure could be significant. The 
explosion resulted in 11 deaths, serious injuries, and the largest oil 
spill in the history of the United States. The response to the 
incident encountered numerous challenges, and by the time the well was 
sealed nearly 3 months later, over 4 million barrels of oil had 
spilled into the Gulf. The spill created significant environmental 
damage and had an adverse impact on workers and businesses, with an 
estimated cost to compensate for these damages totaling billions of 
dollars. 

The U.S. Coast Guard--a component of DHS--is the lead federal agency 
for maritime security, including security of energy tankers and 
offshore energy infrastructure. The FBI--an agency in the Department 
of Justice (DOJ)--shares responsibility with the Coast Guard for 
preventing and responding to terrorist incidents in the maritime 
environment, including incidents involving energy tankers. In December 
2007, we issued a report that examined Coast Guard and FBI efforts to 
prevent and respond to an incident involving energy tankers and we 
made several recommendations to the Coast Guard and the FBI to improve 
efforts in these areas.[Footnote 1] 

My testimony today will address two main objectives: 

* the extent to which the Coast Guard and the FBI have taken actions 
to address our prior recommendations to prevent and respond to 
terrorist incidents involving energy tankers, and: 

* the extent to which the Coast Guard has taken actions to assess the 
security risks to offshore energy infrastructure and the challenges, 
if any, in conducting such assessments. 

My statement is based on our past work on energy tankers issued in 
December 2007 and recently completed work on actions the Coast Guard 
has taken to assess security risks in the maritime environment. 
[Footnote 2] To obtain information on the first objective, we reviewed 
our prior reports on energy tankers, and asked the Coast Guard and the 
FBI to provide us an update, along with supporting documentation, on 
any actions that they have taken to address our recommendations from 
the December 2007 report. To provide additional information on threats 
to energy tankers, we also reviewed our recent work on piracy. 
[Footnote 3] More detailed information on the scope and methodology 
used for our past reviews appears in those reports. 

To address the second objective, we interviewed officials in Coast 
Guard headquarters and field offices in New Orleans, Louisiana and 
Boston, Massachusetts because these officials were knowledgeable about 
how the Coast Guard uses the Maritime Security Risk Analysis Model 
(MSRAM)--a tool that the Coast Guard uses to assess the security risks 
to vessels and offshore energy infrastructure.[Footnote 4] Moreover, 
the New Orleans and Boston field offices are the only offices 
presently conducting assessments of offshore energy infrastructure. We 
also reviewed Coast Guard documents on MSRAM, such as Coast Guard 
guidance to its field units and the MSRAM training manual. In 
addition, we reviewed relevant laws and regulations, policies and 
procedures, and other documents related to security risk assessments. 
For example, we reviewed the DHS Quadrennial Review,[Footnote 5] the 
National Infrastructure Protection Plan,[Footnote 6] and a National 
Research Council report on risk assessments at DHS.[Footnote 7] We 
also reviewed our prior report on risk assessment efforts carried out 
by the Coast Guard.[Footnote 8] In addition, we compared the Coast 
Guard's policies and procedures regarding security actions with 
criteria in Standards for Internal Control in the Federal Government. 
[Footnote 9] Further, we interviewed representatives from two 
companies that together operate 18 of the 50 Outer Continental Shelf 
facilities, a type of offshore energy infrastructure, regulated for 
security in 2011. While the information obtained from these interviews 
is not generalizable to the offshore energy industry as a whole, it 
provided insights into owners' and operators' concerns regarding 
security and actions they have taken to address such concerns. This 
testimony concludes our work on Coast Guard efforts to assess security 
risks for offshore energy infrastructure.[Footnote 10] 

We conducted this performance audit from October 2010 through August 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

The nation's economy and security are heavily dependent on oil, 
natural gas, and other energy commodities. Nearly half of the nation's 
oil is transported from overseas by tankers. For example, about 49 
percent of the nation's crude oil supply--one of the main sources of 
gasoline, jet fuel, heating oil, and many other petroleum products--
was transported by tanker into the United States in 2009.[Footnote 11] 
The remaining oil and natural gas used in the United States comes from 
Canada by pipeline or is produced from domestic sources in areas such 
as offshore facilities in the Gulf of Mexico. With regard to these 
domestic sources, the area of federal jurisdiction--called the Outer 
Continental Shelf (OCS)[Footnote 12]--contains an estimated 85 million 
barrels of oil, more than all onshore resources and those in shallower 
state waters combined.[Footnote 13] In addition, the Louisiana 
Offshore Oil Port (LOOP), a deepwater port, is responsible for 
transporting about 10 percent of imported oil into the United States. 

Federal Agency Roles: 

As the lead federal agency for maritime security, the Coast Guard 
seeks to mitigate many kinds of security challenges in the maritime 
environment. Doing so is a key part of its overall security mission 
and a starting point for identifying security gaps and taking actions 
to address them. Carrying out these responsibilities is a difficult 
and challenging task because energy tankers often depart from foreign 
ports and are registered in countries other than the United States, 
which means the United States has limited authority to oversee the 
security of such vessels until they enter U.S. waters. Offshore energy 
infrastructure also presents its own set of security challenges 
because some of this infrastructure is located many miles from shore. 
The FBI shares responsibility with the Coast Guard for preventing and 
responding to terrorist incidents in the maritime environment, 
including incidents involving energy tankers. 

Risks to Energy Tankers: 

Energy tankers face risks from various types of attack. We identified 
three primary types of attack methods against energy tankers in our 
2007 report, including suicide attacks, armed assaults by terrorists 
or armed bands, and launching a "standoff" missile attack using a 
rocket or some other weapon fired from a distance. In recent years, we 
have issued reports that discussed risks energy tankers face from 
terrorist attacks and attacks from other criminals, such as pirates. 
Terrorists have attempted--and in some cases carried out--attacks on 
energy tankers since September 11, 2001. To date, these attacks have 
included attempts to damage tankers or their related infrastructure at 
overseas ports. For example, in 2002, terrorists conducted a suicide 
boat attack against the French supertanker Limburg off the coast of 
Yemen, and in 2010, an incident involving another supertanker, the M/V 
M. Star, in the Strait of Hormuz is suspected to have been a terrorist 
attack. Our work on energy tankers identified three main places in 
which tankers may be at risk of an attack: (1) at foreign ports; (2) 
in transit, especially at narrow channels, or chokepoints; and (3) at 
U.S. ports. For example, foreign ports, where commodities are loaded 
onto tankers, may vary in their levels of security, and the Coast 
Guard is limited in the degree to which it can bring about 
improvements abroad when security is substandard, in part because its 
activities are limited by conditions set by host nations. In addition, 
while tankers are in transit, they face risks because they travel on 
direct routes that are known in advance and, for part of their 
journey, they may have to travel through waters that do not allow them 
to maneuver away from possible attacks. According to the Energy 
Information Administration, chokepoints along a route make tankers 
susceptible to attacks. Further, tankers remain at risk upon arrival 
in the United States because of the inherent risks to port facilities. 
For example, port facilities are generally accessible by land and sea 
and are sprawling installations often close to population centers. 

Beyond the relatively rare threat of terrorist attacks against 
tankers, the threat of piracy has become relatively common.[Footnote 
14] In particular, piracy threatens tankers transiting one of the 
world's busiest shipping lanes near key energy corridors and the route 
through the Suez Canal. The vast areas at risk for piracy off the Horn 
of Africa, combined with the small number of military ships available 
for patrolling them, make protecting energy tankers difficult. 
According to the International Maritime Bureau, 30 percent (490 of 
1,650) of vessels reporting pirate attacks worldwide from 2006 through 
2010 were identified as tankers.[Footnote 15] See table 1 for a 
summary of tankers attacked by pirates during 2006 through 2010. 

Table 1: Number of Tankers Attacked by Pirates, 2006 - 2010: 

Type of commodity transported: Bitumen[A]; 
2006: 0; 
2007: 1; 
2008: 0; 
2009: 2; 
2010: 2. 

Type of commodity transported: Chemical/Product[B]; 
2006: 35; 
2007: 52; 
2008: 55; 
2009: 69; 
2010: 96. 

Type of commodity transported: Crude Oil; 
2006: 9; 
2007: 25; 
2008: 30; 
2009: 41; 
2010: 43. 

Type of commodity transported: Liquefied Natural Gas; 
2006: 0; 
2007: 1; 
2008: 0; 
2009: 1; 
2010: 1. 

Type of commodity transported: Liquefied Petroleum Gas; 
2006: 4; 
2007: 5; 
2008: 6; 
2009: 5; 
2010: 7. 

Type of commodity transported: Totals; 
2006: 48; 
2007: 84; 
2008: 91; 
2009: 118; 
2010: 149. 

Source: International Maritime Bureau, Piracy and Armed Robbery 
Against Ships Annual Report (United Kingdom, 2010): 

[A] Bitumen is a heavy black viscous oil often used in paving 
materials and sealants. 

[B] This category includes tankers that transport chemicals or oil 
products other than crude oil. 

[End of table] 

As shown in the table, pirate attacks against tankers have tripled in 
the last 5 years, and the incidence of piracy against tankers 
continues to rise. From January through June 2011, 100 tankers were 
attacked, an increase of 37 percent compared to tankers attacked from 
January through June 2010. Figure 1 shows one of the recent suspected 
pirate attacks. In addition, tankers are fetching increasing ransom 
demands from Somali pirates. Media reports indicate a steady increase 
in ransoms for tankers, from $3 million in January 2009 for the Saudi 
tanker Sirius Star, to $9.5 million in November 2010 for the South 
Korean tanker Samho Dream, to $12 million in June 2011 for the Kuwaiti 
tanker MV Zirku. The U.S. Maritime Administration and the Coast Guard 
have issued guidance for commercial vessels to stay 200 miles away 
from the Somali coast. However, pirates have adapted and increased 
their capability to attack and hijack vessels to more than 1,000 miles 
from Somalia using mother ships, from which they launch smaller boats 
to conduct the attacks.[Footnote 16] To address the growing concern 
over piracy, the Coast Guard has issued a directive with guidelines 
for U.S. vessels operating in high-risk waters. This directive 
provides vessel owners and operators with direction for responding to 
emerging security risks. 

Figure 1: Sailors from the U.S. Navy's USS Philippine Sea Rescue Crew 
of the Tanker VLCC Brilliante Virtuoso in Response to a Suspected 
Attack by Pirates, June 2011: 

[Refer to PDF for image: photograph] 

Source: U.S. Navy. 

[End of figure] 

Risks to Offshore Energy Infrastructure: 

Offshore energy infrastructure also faces risks from various types of 
attacks. For example, in 2004, a terrorist attacked an offshore oil 
terminal in Iraq using speedboats packed with explosives, killing two 
U.S. Navy sailors and a U.S. Coast Guardsman. Potential attack methods 
against offshore energy infrastructure identified by the Coast Guard 
or owners and operators include crashing an aircraft into it; using a 
submarine vessel, diver, or other means of attacking it underwater; 
ramming it with a vessel; and sabotage by an employee. Offshore energy 
infrastructure may face security risks because this infrastructure is 
located in open waters and generally many miles away from Coast Guard 
assets and personnel. 

In addition to our work on energy tankers, we have recently completed 
work involving Coast Guard efforts to assess security risks and ensure 
the security of offshore energy infrastructure. Specifically, our work 
focused on two main types of offshore energy infrastructure that the 
Coast Guard oversees for security. The first type are facilities that 
operate on the OCS and are generally described as facilities 
temporarily or permanently attached to the subsoil or seabed of the 
OCS that engage in exploration, development, or production of oil, 
natural gas, or mineral resources.[Footnote 17] As of September 2010, 
there were about 3,900 such facilities, and if a facility of this type 
meets or exceeds any one of three thresholds for production or 
personnel, it is subject to 33 C.F.R. part 106 security requirements. 
[Footnote 18] In this testimony, we focus on the 50 facilities that, 
in 2011, are regulated for security because they meet or exceed the 
threshold criteria. We refer to these security-regulated facilities as 
OCS facilities. The second type of offshore energy infrastructure are 
deepwater ports, which are fixed or floating manmade structures used 
or intended for use as a port or terminal for the transportation, 
storage, or handling of oil or natural gas to any state and includes 
the transportation of oil or natural gas from the United States' OCS. 
[Footnote 19] There are currently four licensed deepwater ports--two 
in the Gulf of Mexico and two in Massachusetts Bay.[Footnote 20] 
Unlike OCS facilities, which are involved in the production of oil or 
natural gas, deepwater ports enable tankers to offload oil or 
liquefied natural gas for transport to land by underwater pipelines. 

Progress Made Addressing Our Recommendations, but Additional Actions 
Could Help Improve Tanker Security: 

In 2007, we assessed Coast Guard and FBI efforts to ensure the 
security of energy tankers and respond to terrorist incidents 
involving energy tankers.[Footnote 21] We found that actions were 
being taken, internationally and domestically, to protect tankers and 
port facilities at which tankers would be present. For example, the 
Coast Guard visits foreign exporting ports to assess the effectiveness 
of the anti-terrorism measures in place. Additionally, port 
stakeholders in the United States have taken steps to address 
vulnerabilities at domestic ports. For example, the Houston Ship 
Channel Security District is a public-private partnership that was 
established to increase preparedness and response capabilities with 
the goal of improving security and safety for facilities, employees, 
and communities surrounding the Houston Ship Channel. The security 
district has installed technology, such as night vision and motion-
activated detection equipment, and conducts patrols on land and in the 
water. However, we also reported on challenges that remained in (1) 
making federal agencies' protective actions more effective and (2) 
implementing plans for a response to an attack, if a terrorist attack 
were to succeed despite the protective measures in place. 

We made five recommendations in our 2007 report, three of which were 
directed to the Secretary of Homeland Security and two of which were 
directed jointly to the Secretary of Homeland Security and the 
Attorney General. The departments concurred or partially concurred 
with all of the recommendations. The Coast Guard and the FBI have made 
progress in implementing these recommendations--two have been 
implemented, and the Coast Guard is in the process of implementing a 
third--but actions have not yet been taken to address the remaining 
two recommendations. See table 2 for a summary of our findings, 
recommendations, and the current status of agency efforts to implement 
our recommendations. 

Table 2: Status of GAO Recommendations on Tanker Security from GAO-08-
141: 

Findings: Resource allocation. Based on Coast Guard records, we found 
that Coast Guard field units in several energy-related ports had been 
unable to accomplish many of the port security responsibilities called 
for in Coast Guard guidance. According to the data we obtained and our 
discussions with field unit officials, we determined that resource 
shortfalls were the primary reasons for not meeting these 
responsibilities. Furthermore, the Coast Guard had not yet developed a 
plan for addressing new liquefied natural gas (LNG) security resource 
demands; 
Recommendation and Status: 
Recommendation: We recommended that the Coast Guard develop a national 
resource allocation plan that would balance the need to meet new LNG 
security responsibilities with existing security responsibilities and 
other Coast Guard missions; 
Status: In progress. The Coast Guard has begun work on a national 
strategy for reducing the maritime security risks present in the bulk 
transportation and transfer of certain dangerous cargoes, including 
LNG. Coast Guard officials expect to finalize the strategy in April 
2012 at which point they expect to develop a resource allocation plan 
to implement the strategy. In the interim, the Coast Guard has 
published guidance to clarify the timing and scope of the process that 
is necessary to ensure full consideration is given to safety and 
security of the port, the facility, and the vessels transporting LNG. 

Findings: Guidance for helping to mitigate economic consequences. We 
reported that the economic consequences of a terrorist attack on a 
tanker could be significant, particularly if one or more ports are 
closed. We identified some ports that, on their own initiative, were 
incorporating economic recovery considerations into their port-level 
plans, but at the time of our review in 2007, there was no national- 
level guidance for use by local ports; 
Recommendation and Status: 
Recommendation: We recommended that the Coast Guard develop guidance 
that ports could use to plan for helping to mitigate economic 
consequences, particularly in the case of port closures; 
Status: Implemented. The Coast Guard and U.S. Customs and Border 
Protection (CBP) have developed Joint Protocols for the Expeditious 
Recovery of Trade. These protocols establish a communications process 
and describe how the Coast Guard and CBP will coordinate with other 
federal agencies and the maritime industry to facilitate recovery and 
resumption of trade following an event that causes a major disruption 
to the maritime transportation system. 

Findings: Integration of spill and terrorism response at the national 
level. We found that while national-and port-level plans exist to 
address spill response or terrorism response, federal agencies and 
ports could face challenges in using them effectively. We reported 
that the separate spill and terrorism response plans should be 
integrated for responding to an attack on an energy commodities tanker; 
Recommendation and Status: 
Recommendation: We recommended that the Coast Guard and the FBI 
coordinate at the national level to help ensure that a detailed 
operational plan be developed that integrates the different spill and 
terrorism sections of the National Response Plan; 
Status: Not implemented. The different spill and terrorism response 
sections of the National Response Plan remain separate annexes in the 
renamed National Response Framework. According to the Coast Guard, the 
National Response Framework is currently under revision, but no 
decision has been made regarding the spill and terrorism response 
annexes. Pending that decision, the FBI has not taken any action to 
implement this recommendation. 

Findings: Integration of spill and terrorism response at the local 
level. In addition to the need for operational plans as noted above, 
we reported that agencies should conduct joint exercises that simulate 
an attack and the agencies' responses. Without such exercises, it 
would be questionable whether joint Coast Guard and FBI activities 
would proceed as planned; 
Recommendation and Status: 
Recommendation: We recommended that the Coast Guard and FBI coordinate 
at the local level to help ensure that spill and terrorism response 
activities are integrated for the best possible response by maximizing 
the integration of spill and terrorism response planning and exercises 
at ports that receive energy commodities where attacks on tankers pose 
a significant threat; 
Status: Implemented. In April 2008, the Coast Guard updated guidance 
which states that the ability to simultaneously execute multiple 
plans, including federal, state, and local response and recovery 
plans, should be part of an overall exercise and preparedness program. 
In accordance with this guidance, the Coast Guard, along with the FBI 
and other stakeholders, has conducted exercises that address an 
integrated spill and terrorism response. 

Findings: Performance measures for emergency response. We found that 
some ports had reported difficulty in securing response resources to 
carry out planned actions and decisions about the need for more 
response capabilities were hindered by a lack of performance measures 
tying resource needs to effectiveness in response; 
Recommendation and Status: 
Recommendation: We recommended that the Secretary of Homeland Security 
work with federal, state, and local stakeholders to develop explicit 
performance measures for emergency response capabilities and use them 
in risk-based analyses to set priorities for acquiring needed response 
resources; 
Status: Not implemented. DHS has not yet developed explicit 
performance measures for emergency response capabilities. According to 
DHS, it is revising its grant programs, but performance measures have 
not yet been developed as part of this effort. 

Source: GAO. 

[End of table] 

Regarding our recommendation that the Coast Guard and the FBI 
coordinate to help ensure that a detailed operational plan be 
developed that integrates the different spill and terrorism sections 
of the National Response Framework, DHS is in the process of revising 
this document and did not have further information regarding whether 
or how the spill and terrorism response annexes may be revised. 
Further, the FBI has not taken independent action to implement this 
recommendation, in part because it did not concur with the need to 
develop a separate operational plan. In the event of a successful 
attack on an energy tanker, ports would need to provide an effective, 
integrated response to (1) protect public safety and the environment, 
(2) conduct an investigation, and (3) restore shipping operations in a 
timely manner. Consequently, clearly defined and understood roles and 
responsibilities for all essential stakeholders are needed to ensure 
an effective response, and operational plans for the response should 
be explicitly linked. Regarding our recommendation that DHS develop 
performance measures for emergency response capabilities, DHS has 
begun to revise its grant programs, but it is too early in that 
process to determine whether and how performance measures will be 
incorporated into those revisions. Performance measures would allow 
DHS to set priorities for funding on the basis of reducing overall 
risk, thereby helping ports obtain resources necessary to respond. We 
continue to believe that the recommendations not yet addressed have 
merit and should be fully implemented. 

Coast Guard Had Not Assessed Risks to All OCS Facilities: 

In accordance with federal statutes and presidential directives, the 
Coast Guard assesses security risks as part of its responsibilities 
for ensuring the security of OCS facilities and deepwater ports. In 
doing so, the Coast Guard, among other things, uses a tool called the 
Maritime Security Risk Analysis Model (MSRAM). Coast Guard units 
throughout the country use this tool to assess security risks to about 
28,000 key infrastructure in and around the nation's ports and 
waterways. For example, MSRAM examines security risks to national 
monuments, bridges, and oil and gas terminals. 

The Coast Guard's efforts to assess security risks to OCS facilities 
and deepwater ports are part of a broader effort by DHS to protect 
critical infrastructure and key resources.[Footnote 22] To further 
guide this effort, in 2009 DHS issued an updated version of the 2006 
National Infrastructure Protection Plan which describes the 
department's strategic approach to infrastructure protection.[Footnote 
23] The plan placed an increased emphasis on risk management and it 
centered attention on going beyond assessments of individual assets by 
extending the scope of risk assessments to systems or networks. 
[Footnote 24] For example, while the 2006 plan focused on assessing 
the vulnerability of facilities, the 2009 plan discussed efforts to 
conduct systemwide vulnerability assessments. 

Progress Made Assessing Offshore Security Risks: 

The Coast Guard has taken a number of actions in assessing security 
risks to OCS facilities and deepwater ports. The Coast Guard has used 
MSRAM to, among other things, examine security risks to OCS facilities 
and deepwater ports by assessing three main factors--threats, 
vulnerabilities, and consequences.[Footnote 25] First, Coast Guard 
analysts use MSRAM to assess security risks against such energy 
infrastructure by examining potential scenarios terrorists may use to 
attack OCS facilities or deepwater ports. For example, MSRAM assesses 
attack scenarios, such as an attack by a hijacked vessel, a small boat 
attack, sabotage, or an attack by a swimmer or diver. Second, the 
analysts use MSRAM to evaluate vulnerabilities of OCS facilities and 
deepwater ports by examining the probability of a successful attack by 
assessing factors such as the ability of key stakeholders, including 
the owner, operator, or law enforcement, to interdict an attack and 
the ability of a target to withstand an attack. Third, the analysts 
use MSRAM to evaluate potential consequences of an attack, such as 
deaths or injuries and economic and environmental impacts.[Footnote 
26] MSRAM's output produces a risk index number for each maritime 
target--such as an OCS facility or deepwater port--that allows Coast 
Guard officials at the local, regional, and national levels to compare 
and rank critical infrastructure for the purpose of informing security 
decisions. According to Coast Guard officials, based on MSRAM's 
output, which is a relative risk ranking, OCS facilities are not 
considered to be high-risk targets. 

To inform analysts' inputs into MSRAM, the Coast Guard has coordinated 
efforts with the intelligence community and key stakeholders. For 
example, the Coast Guard's Intelligence Coordination Center inputs 
threat assessment data into MSRAM. Coast Guard analysts also use 
information from other stakeholders, such as reports produced by the 
Department of the Interior's Bureau of Ocean Energy Management, 
Regulation and Enforcement (BOEMRE), which contain oil and gas 
production data, to inform their evaluations of vulnerabilities and 
consequences. Based on the assessments of threats, vulnerabilities, 
and consequences, MSRAM produces a risk index number for each OCS 
facility and deepwater port. The Coast Guard has also taken actions to 
supplement MSRAM by, among other things, (1) including new data fields 
on the frequency with which tankers visit a port and (2) adding 
additional threat scenarios, such as a threat involving a cyber 
attack, to its data set. 

While MSRAM has been applied to deepwater ports, Coast Guard officials 
have also used an independent risk assessment to assess security risks 
as part of the application process for recently constructed deepwater 
ports. For example, in December 2006, as part of the application 
process for a proposed deepwater port in the Massachusetts Bay, the 
Coast Guard, the owner and operator, and other stakeholders 
collectively identified and assessed threat scenarios as well as the 
potential consequences and vulnerabilities of each scenario. Based on 
this assessment, stakeholders identified and agreed to carry out 
security measures to mitigate the risks, such as installing camera 
systems and increasing radar coverage. 

Challenges in Data and Scope Hinder Risk Assessments: 

The Coast Guard faces complex and technical challenges in assessing 
security risks. The Coast Guard recognizes these challenges and 
generally has actions underway to study or address them. Coast Guard 
officials noted that some of these challenges are not unique to the 
Coast Guard's risk assessment model and that these challenges are 
faced by others in the homeland security community involved in 
conducting risk assessments. Specific challenges are detailed below. 

Challenges in Data: 

* Vulnerability-related data: The Coast Guard does not have data on 
the ability of an OCS facility to withstand an attack, which is 
defined in MSRAM as target hardness. The Coast Guard recognizes that 
target hardness is an important consideration in assessing the 
vulnerability of OCS facilities. However, MSRAM analysts described 
challenges in assessing target hardness because empirical data are not 
available or research has not been conducted to do so. For example, 
research on whether a hijacked boat or an underwater attack could sink 
an offshore oil or natural gas platform would give the Coast Guard and 
owners and operators a clearer sense of whether this attack scenario 
could result in major consequences. Coast Guard officials and 
corporate security officers with whom we spoke indicated that such 
research would advance knowledge about the vulnerabilities of OCS 
facilities and deepwater ports. Gaining a better understanding of 
target hardness of these and other threat scenarios could improve the 
quality of the output from MSRAM. According to Coast Guard's MSRAM 
Program Manager, the Coast Guard may recommend conducting more 
research on the vulnerability to and consequences of attack scenarios 
as a result of a study it is currently conducting on OCS facilities in 
the Gulf of Mexico. The Coast Guard initiated this study in the fall 
of 2010 after the Deepwater Horizon incident. The study initially 
reviewed the "lessons learned" from Deepwater Horizon and how those 
lessons could be used to improve MSRAM. During the course of our 
review, Coast Guard officials stated that the scope of the study has 
been expanded to include OCS facilities and that the Coast Guard 
expects to issue its report in the fall of 2011. 

* Consequences-related data: The input for secondary economic impacts 
[Footnote 27] can have a substantial effect on how MSRAM's output 
ranks a facility relative to other potential targets. Undervaluing 
secondary economic impacts could result in a lower relative risk 
ranking that underestimates the security risk to a facility, or 
inversely, overvaluing secondary economic impacts could result in 
overestimating the security risk to a facility. However, the Coast 
Guard has limited data for assessing secondary economic impacts from 
an attack on OCS facilities or deepwater ports. Coast Guard analysts 
stated that gathering these data is a challenge because there are few 
models or guidance available for doing so. During the course of our 
review, the Coast Guard started using a tool, called "IMPLAN," that 
helps inform judgments of secondary economic impacts by showing what 
the impact could be for different terrorist scenarios.[Footnote 28] 
The tool, however, has limits in that it should not be used where the 
consequences of a terrorist attack are mainly interruption to land or 
water transportation. Enhancing DHS's and the Coast Guard's ability to 
assess secondary economic impacts could improve a MSRAM analyst's 
accuracy in assessing the relative risk of a particular target. Coast 
Guard officials added that they are working with DHS's Office of Risk 
Management and Analysis in studying ways to improve how it assesses 
secondary economic impacts. 

Challenges in Scope: 

* Challenges in assessing security risks to OCS facilities: We 
determined that the Coast Guard did not conduct MSRAM assessments for 
all 50 of the OCS facilities that are subject to federal security 
requirements in 2011. Coast Guard guidance calls for MSRAM analysts to 
identify and assess all significant targets that fall within a unit's 
area of responsibility, which includes all security-regulated OCS 
facilities. Specifically, as of May 2011, we found that MSRAM did not 
include 12 of the 50 OCS facilities operating at that time. Coast 
Guard officials generally agreed with our finding and they have since 
incorporated these 12 facilities into MSRAM and completed the required 
risk assessments. While the Coast Guard plans to update its policies 
and procedures for inspecting and ensuring the security of OCS 
facilities in the future, the current set of policies and procedures 
do not call for an updated list of OCS facilities to be provided to 
MSRAM analysts to assess the security risks to such facilities 
annually. Coast Guard officials acknowledged that their policies and 
procedures did not include this requirement. Revising policies and 
procedures to include such a requirement is important in that the 
number of OCS facilities could change each year. For example, some 
facilities may drop below the production or personnel thresholds 
described earlier in this statement, thereby falling outside the scope 
of 33 C.F.R. part 106, or other facilities could meet or exceed such 
thresholds, thereby rendering them subject to part 106. Standards for 
Internal Control in the Federal Government state that policies and 
procedures enforce management directives and help ensure that actions 
are taken to address risks.[Footnote 29] In addition, internal control 
standards state that such control activities are an integral part of 
an entity's planning, implementing, reviewing, and accountability for 
stewardship of government resources and for achieving effective 
results. Developing such procedures could help ensure that the Coast 
Guard carries out its risk assessment requirements for such security-
regulated OCS facilities. 

* Challenges in assessing security risks to offshore energy 
infrastructure that is not subject to security requirements: With 
respect to OCS facilities, analysts only use MSRAM to assess security 
risks associated with those OCS facilities that are regulated for 
security under 33 C.F.R. part 106. For example, the Deepwater Horizon 
did not meet the threshold criteria subjecting it to regulation under 
part 106, and therefore, MSRAM was not used to assess its security 
risks (see figure 2 for a photo of the Deepwater Horizon explosion). 
According to Coast Guard officials, mobile offshore drilling units 
(MODUs), such as the Deepwater Horizon, do not generally pose a risk 
of a terrorist attack since there is little chance of an oil spill 
when these units are drilling and have not struck oil.[Footnote 30] 
However, the officials noted that there is a brief period of time when 
a drilling unit strikes a well, but the well has yet to be sealed 
prior to connecting it to a production facility. The Deepwater Horizon 
was in this stage when it resulted in such a large oil spill. During 
that period of time, MODUs could be at risk of a terrorist attack that 
could have significant consequences despite a facility not meeting the 
production or personnel thresholds. For example, such risks could 
involve the reliability of blowout preventer valves--specialized 
valves that prevent a well from spewing oil in the case of a blowout. 
Gaining a fuller understanding of the security risks associated with 
MODUs, such as the Deepwater Horizon, could improve the quality of 
program decisions made by Coast Guard managers on whether actions may 
be needed to ensure the security of this type of facility. According 
to Coast Guard officials, they are studying the "lessons learned" from 
the Deepwater Horizon incident and part of the study involves 
examining whether analysts should use MSRAM to assess MODUs in the 
future. 

Figure 2: Explosion of the Deepwater Horizon Drilling Unit in the Gulf 
of Mexico, April 2010: 

[Refer to PDF for image: photograph] 

Source: U.S. Coast Guard. 

[End of figure] 

* Challenges in assessing systemic or network risks: MSRAM does not 
assess systemic or network risks because, according to Coast Guard 
officials, these types of assessments are beyond the intended use of 
MSRAM. The 2009 National Infrastructure Protection Plan, 2010 DHS 
Quadrennial Review,[Footnote 31] and a National Research Council 
evaluation of DHS risk assessment efforts[Footnote 32] have determined 
that gaining a better understanding of network risks would help to 
understand multiplying consequences of a terrorist attack or 
simultaneous attacks on key facilities. Understanding "network" risks 
involves gaining a greater understanding of how a network is 
vulnerable to a diverse range of threats. Examining how such 
vulnerabilities create strategic opportunities for intelligent 
adversaries with malevolent intent is central to this understanding. 
For example, knowing what damage a malicious adversary could achieve 
by exploiting weaknesses in an oil-distribution network offers 
opportunities for improving the resiliency of the network within a 
given budget.[Footnote 33] 

How the Coast Guard assesses offshore infrastructure within the 
broader set of networks is important. The findings of the National 
Commission on the BP Deepwater Horizon Oil Spill incident illustrate 
how examining networks or systems from a safety or engineering 
perspective can bring greater knowledge of how single facilities 
intersect with broader systems.[Footnote 34] The report noted that 
"complex systems almost always fail in complex ways" and cautioned 
that attempting to identify a single cause for the Deepwater Horizon 
incident would provide a dangerously incomplete picture of what 
happened. As a result, the report examined the Deepwater Horizon 
incident with an expansive view toward the role that industry and 
government sectors played in assessing vulnerabilities and the impact 
the incident had on economic, social, and environmental systems. 
Enhancing knowledge about the vulnerabilities of networks or systems 
with which OCS facilities and deepwater ports intersect could improve 
the quality of information that informs program and budget decisions 
on how to best ensure security and use scarce resources in a 
constrained fiscal environment. Doing so would also be consistent with 
DHS's Quadrennial Review and other DHS guidance and would provide 
information to decision makers that could minimize the likelihood of 
being unprepared for a potential attack. Coast Guard officials agreed 
that assessing "network effects" is a challenge and they are examining 
ways to meet this challenge. However, the Coast Guard's work is this 
area is in its infancy and there is uncertainty regarding the way in 
which the Coast Guard will move forward in measuring "network effects." 

Conclusions: 

The threat of terrorism against energy tankers and offshore energy 
infrastructure highlights the importance of the Coast Guard having 
policies and procedures in place to better ensure the security of 
energy tankers, OCS facilities, and deepwater ports. The Coast Guard 
has taken steps to implement prior GAO recommendations to enhance 
energy tanker security, and it continues to work towards implementing 
the three outstanding recommendations. Improvements in security could 
help to prevent a terrorist attack against this infrastructure, which 
could have significant consequences, such as those resulting from the 
Deepwater Horizon incident. While the Coast Guard does not consider 
OCS facilities that it has assessed in MSRAM to be high risk, it is 
important to assess all OCS facilities as required by Coast Guard 
guidance. Since May 2011, when we determined that some OCS facilities 
were not assessed, the Coast Guard has completed its assessments for 
the previously omitted facilities. However, given that the list of 
security-regulated facilities may change each year based on factors 
such as production volume, it is important to ensure that any 
facilities added to the list in the future will be assessed for 
security risks in MSRAM. By revising policies and procedures to help 
ensure that an updated list of OCS facilities is provided to MSRAM 
analysts on an annual basis, the Coast Guard would be better 
positioned to ensure that all risk assessments for facilities 
requiring such assessments be conducted in a manner consistent with 
the law and presidential directive. 

Recommendations for Executive Action: 

To strengthen the Coast Guard's efforts to assess security risks and 
ensure the security of OCS facilities, we recommend that the 
Commandant of the Coast Guard revise policies and procedures to ensure 
that MSRAM analysts receive the annual updated list of security-
regulated OCS facilities to ensure that risk assessments have been 
conducted on all such OCS facilities. 

Agency Comments and Our Evaluation: 

We provided a draft of this testimony to DHS and DOJ for comment. The 
Coast Guard concurred with our recommendation to revise policies and 
procedures to ensure that MSRAM analysts receive the annual updated 
list of security-regulated OCS facilities. DHS and DOJ provided oral 
and technical comments, which we incorporated as appropriate. 

Chairman McCaul, Ranking Member Keating, and Members of the 
Subcommittee, this concludes my prepared statement. This testimony 
concludes our work on Coast Guard efforts to assess security risks for 
offshore energy infrastructure. However, we will continue our broader 
work looking at the security of offshore energy infrastructure, 
including Coast Guard security inspections and other challenges. Our 
evaluation will focus on Coast Guard security inspections and other 
measures to better secure OCS facilities and deepwater ports.[Footnote 
35] We will continue to work with the Coast Guard to develop solutions 
to ensure that inspections of OCS facilities are completed as required. 

I would be happy to respond to any questions you may have. 

GAO Contact and Staff Acknowledgments: 

Key contributors to this testimony were Christopher Conrad, Assistant 
Director; Neil Asaba, Analyst-in-Charge; Alana Finley; Christine Kehr; 
Colleen McEnearney; Erin O'Brien; Jodie Sandel; and Suzanne Wren. 
Chuck Bausell contributed economics expertise, Pamela Davidson 
assisted with design and methodology, Tom Lombardi provided legal 
support, and Jessica Orr provided assistance in testimony preparation. 

[End of section] 

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http://www.gao.gov/products/GAO-11-449T]. Washington, D.C.: March 15, 
2011. 

Quadrennial Homeland Security Review: 2010 Reports Addressed Many 
Required Elements, but Budget Planning Not Yet Completed. [hyperlink, 
http://www.gao.gov/products/GAO-11-153R]. Washington, D.C.: December 
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[End of section] 

Footnotes: 

[1] GAO, Maritime Security: Federal Efforts Needed to Address 
Challenges in Preventing and Responding to Terrorist Attacks on Energy 
Commodity Tankers, [hyperlink, http://www.gao.gov/products/GAO-08-141] 
(Washington, D.C.: Dec. 10, 2007). 

[2] [hyperlink, http://www.gao.gov/products/GAO-08-141]. 

[3] GAO, Maritime Security: Actions Needed to Assess and Update Plan 
And Enhance Collaboration among Partners Involved in Countering Piracy 
off the Horn of Africa, [hyperlink, 
http://www.gao.gov/products/GAO-10-856] (Washington, D.C.: Sept. 24, 
2010); and Maritime Security: Updating U.S. Counterpiracy Action Plan 
Gains Urgency as Piracy Escalates off the Horn of Africa, [hyperlink, 
http://www.gao.gov/products/GAO-11-449T] (Washington, D.C.: Mar. 15, 
2011). 

[4] In looking at the Coast Guard's assessments of risks, we focused 
on security risks--risks emanating from terrorists or others that 
would purposely attack or sabotage offshore energy infrastructure. We 
did not focus on accidental risks to such infrastructure. However, we 
have ongoing work to assess industry plans for developing new methods 
or technologies to control and contain blowouts occurring in subsea 
environments. We are conducting this work at the request of the 
Ranking Member of the House Committee on Energy and Commerce. We 
expect to issue this related report in the winter of 2012. We are also 
conducting broader work examining the Coast Guard's use of MSRAM for 
the Chairman of the Senate Committee on Commerce, Science, and 
Transportation; the Ranking Member of the Senate Committee on Homeland 
Security and Governmental Affairs; and the Chairwoman of the House 
Homeland Security Committee, Subcommittee on Border and Maritime 
Security. We expect to issue this report later in 2011. 

[5] The DHS Quadrennial Review outlines a strategic framework for 
stakeholders, including federal, state, local, tribal, territorial, 
nongovernmental, and private-sector entities, in responding to 
security threats. For more information about the DHS Quadrennial 
Review, see GAO, Quadrennial Homeland Security Review: 2010 Reports 
Addressed Many Required Elements, but Budget Planning Not Yet 
Completed, [hyperlink, http://www.gao.gov/products/GAO-11-153R] 
(Washington, D.C.: Dec. 16, 2010). 

[6] The National Infrastructure Protection Plan represents a strategy 
for protecting critical infrastructure and key resources, and it 
offers a framework for assessing risk. For more information about the 
National Infrastructure Protection Plan, see GAO, Critical 
Infrastructure Protection: Update to National Infrastructure 
Protection Plan Includes Increased Emphasis on Risk Management and 
Resilience, [hyperlink, http://www.gao.gov/products/GAO-10-296] 
(Washington, D.C.: Mar. 5, 2010). 

[7] National Research Council: Review of the Department of Homeland 
Security's Approach to Risk Analysis (Washington, D.C.: 2010). 

[8] GAO, Risk Management: Further Refinements Needed to Assess Risks 
and Prioritize Protective Measures at Ports and Other Critical 
Infrastructure, [hyperlink, http://www.gao.gov/products/GAO-06-91] 
(Washington, D.C.: Dec. 15, 2005) and Maritime Security: DHS Progress 
and Challenges in Key Areas of Port Security, [hyperlink, 
http://www.gao.gov/products/GAO-10-940T] (Washington, D.C.: July 21, 
2010). 

[9] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[10] We will continue our broader work looking at the security of 
offshore energy infrastructure, including Coast Guard security 
inspections and other challenges. 

[11] This figure is based on the most recently available data for a 
full year from the U.S. Energy Information Administration. 

[12] The OCS is a designation for all submerged lands of which the 
subsoil and seabed are outside the territorial jurisdiction of a U.S. 
state, but within U.S. jurisdiction and control. 

[13] Based on an estimate from the National Commission on the BP 
Deepwater Horizon Oil Spill and Offshore Drilling, Deep Water: The 
Gulf Oil Disaster and the Future of Offshore Drilling (Washington, 
D.C.: January 2011). 

[14] The motivation behind an attack may distinguish piracy from 
terrorism. For example, the motivation for piracy is often monetary, 
whereas terrorism is politically motivated. 

[15] The International Chamber of Commerce's International Maritime 
Bureau operates a Piracy Reporting Center that collects data on pirate 
attacks worldwide. 

[16] For more information on U.S. government efforts to combat piracy, 
see [hyperlink, http://www.gao.gov/products/GAO-10-856], which 
discusses the Coast Guard's and other agencies' progress in 
implementing efforts to prevent piracy attacks. This report contains 
recommendations to improve U.S. government efforts to combat piracy. 

[17] See 33 C.F.R. § 106.105. 

[18] Facilities meeting any of the threshold criteria are often 
referred to as Maritime Transportation and Security Act (MTSA)- 
regulated facilities. The production or personnel thresholds for 
determining whether an OCS facility will be subject to security 
requirements in accordance with 33 C.F.R. part 106 are: (1) producing 
greater than 100,000 barrels of oil a day, (2) producing more than 200 
million cubic feet of natural gas per day, or (3) hosting more than 
150 persons for 12 hours or more in each 24 hour period continuously 
for 30 days or more. According to 33 C.F.R. § 140.10, production means 
those activities which take place after the successful completion of 
any means for the removal of minerals, including, but not limited to, 
such removal, field operations, transfer of minerals to shore, 
operation monitoring, maintenance, and workover. According to the 
Coast Guard, the statement; "transfer of minerals to shore" 
encompasses fixed facilities that operate as "Transmission 
Facilities." Production quantities shall be calculated as the sum of 
all sources of production from wells on the primary and any attending 
platform(s), including the throughput of other pipelines transferring 
product across the same platform(s). 

[19] See 33 C.F.R. § 148.5. Although deepwater ports are generally not 
regulated for security in accordance with MTSA, owners and operators 
generally carry out similar measures to those carried out for OCS 
facilities by, among other things, developing security plans 
comparable to those implemented by OCS facilities pursuant to part 
106. See 33 C.F.R. § 150.15(x). 

[20] According to the Coast Guard, one of the Gulf of Mexico deepwater 
ports is expected to be decommissioned in the near future. 

[21] [hyperlink, http://www.gao.gov/products/GAO-08-141].  

[22] The Homeland Security Act of 2002, enacted the same day as MTSA 
(November 25, 2002), established DHS and gave the department wide- 
ranging responsibilities for, among other things, leading and 
coordinating the overall national critical infrastructure protection 
effort. Title II of the Homeland Security Act, as amended, primarily 
addresses the department's responsibilities for critical 
infrastructure protection. According to DHS, there are thousands of 
facilities in the United States that if degraded or destroyed by a 
manmade or natural disaster could cause some combination of 
significant casualties, major economic losses, or widespread and long-
term disruptions to national well-being and governance capacity. 

[23] DHS, National Infrastructure Protection Plan, Partnering to 
Enhance Protection and Resiliency (Washington, D.C: January 2009). 
This plan represents a strategy for protecting critical infrastructure 
and key resources and it offers a framework for assessing risk. DHS 
issued the original plan in June 2006. 

[24] Network effects involve the ripple effect of an incident or 
simultaneous incidents on key sectors of the economy. For example, 
production facilities, pipelines, transfer stations, and refineries 
are part of the oil and natural gas network in and around the Gulf of 
New Mexico. Assessing network effects could involve determining 
whether a terrorist attack on a few key assets would have a 
disproportionate effect on the performance of this network. Such an 
assessment could examine the degree to which such an incident could 
disrupt the flow of oil or natural gas to industries that use these 
types of energy as inputs to their production functions. 

[25] DHS defines threat as a natural or manmade occurrence, 
individual, entity, or action that has or indicates the potential to 
harm life, information, operations, the environment, and/or property. 
For the purpose of calculating risk, the threat of an intentional 
hazard is generally estimated as the likelihood of an attack being 
attempted by an adversary; for other hazards, threat is generally 
estimated as the likelihood that a hazard will manifest itself. In the 
case of terrorist attacks, the threat likelihood is estimated based on 
the intent and capability of the adversary. DHS defines vulnerability 
as a physical feature or operational attribute that renders an entity 
open to exploitation or susceptible to a given hazard. In calculating 
the risk of an intentional hazard, a measure of vulnerability is the 
likelihood that an attack is successful, given that it is attempted. 
DHS defines consequence as the effect of an event, incident, or 
occurrence; reflects the level, duration, and nature of the loss 
resulting from the incident. For the purposes of the National 
Infrastructure Protection Plan, consequences are divided into four 
main categories: public health and safety (i.e., loss of life and 
illness); economic (direct and indirect); psychological; and 
governance/mission impacts. 

[26] MSRAM assesses consequences of six factors: (1) deaths and 
injuries, (2) primary economic impact, (3) environmental impact, (4) 
national security impacts, (5) symbolic impacts, and (6) secondary 
economic impacts. 

[27] According to the Coast Guard, secondary economic impacts are a 
factor representing a description of follow-on economic effects of a 
successful attack. 

[28] IMPLAN stands for IMpact Analysis for PLANning. It is a tool that 
assesses economic relationships between primary economic impacts and 
secondary economic impacts. 

[29] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[30] MODUs engage in drilling rather than production. 

[31] U.S. Department of Homeland Security: Quadrennial Homeland 
Security Review Report: A Strategic Framework for a Secure Homeland 
(Washington D.C.: February 2010). 

[32] National Research Council: Review of the Department of Homeland 
Security's Approach to Risk Analysis (Washington D.C.: 2010). 

[33] See Gerald G. Brown, W. Matthew Carlyle, Javier Salmerón, and 
Kevin Wood, Operations Research Department, Naval Postgraduate School: 
Analyzing the Vulnerability of Critical Infrastructure to Attack and 
Planning Defenses (Monterrey, California: 2005). According to DHS, 
resiliency is the ability to resist, absorb, recover from, or 
successfully adapt to adversity or a change in conditions. 

[34] National Commission on the BP Deepwater Horizon Oil Spill and 
Offshore Drilling, Deep Water: The Gulf Oil Disaster and the Future of 
Offshore Drilling (Washington D.C.: January 2011). 

[35] We are conducting this work for the Chairman of the Senate 
Committee on Commerce, Science, and Transportation; the Ranking Member 
of the Senate Committee of Homeland Security and Governmental Affairs; 
the House Committee on Energy and Commerce; the Chairman of the House 
Committee on Transportation and Infrastructure; the Ranking Member of 
the House Committee on Homeland Security; and the Ranking Member of 
the House Committee on Natural Resources; and the Chairman of the 
House Homeland Security Committee's Subcommittee on Oversight, 
Investigations, and Management. 

[End of section] 

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