CISA Publishes New 60-day ICR Notice for Infrastructure Visualization Platform
Yesterday, CISA published a new 60-day information collection request (ICR) in the Federal Register (89 FR 44695-44696) for Infrastructure Visualization Platform (IVP) Pre-Collection Questionnaire. This new ICR will support critical infrastructure security assessment efforts by CISA’s Protective Security Advisors (PSA). The collection would be for the facility questionnaire that would have to be filled out before the on-sight data collection would take place.
CISA provides the following burden estimates to support this ICR.
NOTE: The annualized respondent cost appears to be the standard calculation for personnel costs for the time to fill out the questionnaire.
A copy of the questionnaire that is covered by this ICR notice will not be publicly available until CISA submits the ICR to OIRA after the 30-day ICR notice is published.
Background
I first ran across a discussion of this new program back in 2020 during the 2020 Chemical Security Summit. In that blog post I described the program as “an interactive visual look at an infrastructure location; think Google Street View® that includes inside the gates with interior shots.”
CISA’s IVP web page provides a more in depth description, concluding with:
“The final product is a portable, interactive document containing the imagery, data, and analysis of the facility that is provided to the requesting stakeholder, typically a facility representative, or special event security planning personnel. This information assists these users in training, planning, and making informed incident preparedness and management decisions. Other Cyber Security and infrastructure Security Agency assessments, such as Regional Resiliency Assessment Program documents and Infrastructure Survey Tools can be added to the IVP producing a single interactive product.”
CISA’s IVP Fact Sheet explains that:
“When conducting an imagery captures the IVP team considers two viewpoints: hostile target and civil response. For the hostile target viewpoint in which a facility or building is viewed as a tactical objective, the team collects multimedia data to document approach and exit routes, use of lighting, visible and hidden entrances, loading docks, and parking garages. In considering the civil response viewpoint, the team collects data on obstructions and restrictions that would affect the approach of emergency response vehicles, equipment to the site, and street or parking accessibility in proximity to building access points. Additional data collected includes relevant “areas of emphasis,” such as exterior and interior critical support equipment (e.g., water valves, electrical shut-off panels, backup generators), personnel emergency marshaling points, and control centers.”
This sounds like an ideal tool for use with emergency response coordination and training. It could also be effectively used in training exercises. For high-profile exercises, where the potential costs could be more easily justified, it would be interesting to see if animations could be added to the display to show adversarial actions being undertaken.
Public Comments
CISA is soliciting public comment on this ICR notice. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # CISA-2024-0012). Comments should be submitted by July 22nd, 2024.