DHS Publishes NIPP Change Notice

Today the DHS National Protection and Programs Directorate (NPPD) published a notice in the Federal Register (78 FR 34112-34115) requesting public comments on their planned changes to the National Infrastructure Protection Plan (NIPP). This revision of the NIPP was mandated by the President’s Presidential Policy Directive (PPD) 21, Critical Infrastructure Security and Resilience, that was published concurrently with the Cybersecurity EO (EO 13636).

The current version of the NIPP was published in 2009 after the triennial review. There was a short public comment period for that revision, but it was preceded by a comment period on the actual review. Neither comment period produced a lot in the way of responses.

The Proposed Changes

This notice provides a list of changes that the Department knows will be included in the revision. This include:

• Changes to the sectors and designated SSAs;

• Changes in terminology based on recent directives;

• Alignment with PPD-8 on National Preparedness;

• Updates to information-sharing tools and mechanisms;

• Critical infrastructure security and resilience regulatory programs;

• Updates on measurement and reporting and risk-informed resource allocation;

• Review and update cycles for the NIPP and Sector-Specific Plans (SSPs);

• Closer integration of physical and cybersecurity, including increased coordination of research and development efforts;

• Review of the risk management approach;

• Sector dependencies on energy and communications systems;

• Increased regional emphasis of critical infrastructure security and resilience; and

• Other issues, such as aging infrastructure and climate change adaptation.

The links provided above only provide a very general overview of the changes that NPPD intends to make in the NIPP. I’m not sure how DHS expects the public to intelligently comment on the changes with such little information provided.

Public Comments

Public comments are being solicited on the proposed revision of the NIPP. Such comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # DHS-2013-0024) and need to be submitted by July 8^th. This short comment period is driven by the 240 day requirement in PPD-8 for the Secretary to have this revision submitted to the President.

I suppose that we should be grateful that a public comment period is provided at all. Comments should be relatively easy to formulate due to the lack of information upon which to comment.