National Cybersecurity Incident Response Plan

RADM (Ret.) Mark Montgomery, Annie Fixler, Jiwon Ma

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Public Comment on the National Cybersecurity Incident Response Plan

The Foundation for Defense of Democracies (FDD) Center on Cyber and Technology Innovation appreciates the opportunity to comment on the draft National Cybersecurity Incident Response Plan (NCIRP).

The leadership of the Cybersecurity and Infrastructure Security Agency (CISA) in coordinating stakeholder and interagency engagement in drafting the NCIRP has been exceptional. As the designated National Coordinator for the security and resilience of the nation’s critical infrastructure, the agency has demonstrated the ability to manage and coordinate responses to cyber threats across both the public and private sectors. The NCIRP, as drafted, provides a strong foundation and serves as a testament to CISA’s dedication and its demonstrated capabilities over the years.

A clear and effective national response framework is critical for ensuring a well-coordinated response to cyber incidents threatening the security of U.S. critical infrastructure. The NCIRP could be refined further to provide greater clarity around the roles and responsibilities of key entities. Following the issuance of the final draft, we look forward to the implementation plans that will operationalize this framework.

Further Recognition of Space as a Critical Infrastructure

One notable aspect of the plan is its recognition of the space domain as a critical asset to our country. Space assets provide essential services for infrastructure systems we rely on every day, such as global positioning, satellite communications, and remote sensing, which support transportation, energy, emergency response, financial systems, and much more. Disruptions to these assets could have cascading effects across various sectors. However, the NCIRP’s acknowledgment of this fact falls short of the needed step of formally designating space systems as critical infrastructure. National Security Memorandum 22 similarly fails to include space as a critical infrastructure, but this does not diminish its importance in national security.