MINUTES OF THE 15 FEBRUARY 1985 MEETING OF THE NTISSC

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP87M00220R000100170025-6
• Release Decision: RIPPUB
• Original Classification: U
• Document Page Count: 52
• Document Creation Date: December 27, 2016
• Document Release Date: November 23, 2010
• Sequence Number: 25
• Publication Date: March 4, 1985
• Content Type: MEMO

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STAT
NTISSC OFFICE OF THE EXECUTIVE SECRETARY
NATIONAL
TELECONNIUNICAT10?4
AND
INFOSUAAT1011 SYSTEMS
WWWW
=WWTTEE
NTISSC 10-85
4 March 1985
MEMORANDUM FOR THE MEMBERS AND OBSERVERS, NATIONAL
TELECOMMUNICATIONS AND INFORMATION SYSTEMS SECURITY COMMITTEE
)6S1?
SUBJECT: Minutes of the 15 February 1985 Meeting of the NTISSC
This memorandum forwards the minutes of the second meeting
of the NTISSC, held on 15 February 1985. If no written corrections
or changes to these minutes are received by 22 March 1985, they
will stand as written.
Atch:
Meeting Minutes w/1 Enclosure
TORZTETTC111-L--USE?ANLY-
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MINUTES OF THE 15 FEBRUARY 1985 MEETING
OF THE NATIONAL TELECOMMUNICATIONS AND INFORMATION
SYSTEMS SECURITY COMMITTEE (NTISSC)
1. The second meeting of the NTISSC was held on Friday,
15 February 1985, at the Federal Aviation Administration (FAA)
building. With the exception of the NSC representative, all
other agency and department representatives and observers were
present.
2. The Chairman opened the meeting with an expression of
appreciation to the Transportation representative for hosting
the Committee meeting, after which the Transportation representa-
tive welcomed the Committee to the FAA facility.
3. NTISSC's meeting schedule for the remainder of 1985
was provided by the Chairman. The NTISSC will meet again on
10 May, 9 August and 8 November 1985, from 0900 to 1100 hours.
Notification of meeting location(s) will be forwarded with each
meeting agenda.
4. Two items on the subject of membership were next addressed:
a. The Chairman announced that the U.S. Nuclear
Regulatory Commission (NRC) had joined the NTISSC in an observer
status and introduced NRC's representative, Mr. Raymond J. Brady.
b. The second item regarding membership was
Mr. William J. Casey's request to Secretary Weinberger for the
Director of Central Intelligence (DCI) to have two representatives
on the NTISSC and its subcommittees. The Chairman stated that
the Central Intelligence Agency is currently represented on the
Committee, and it was Mr. Casey's request that the Intelligence
Community (IC) Staff also be represented. The Chairman went on
to say that in the NTISSC Governing Procedures there existed a
provision for this request, and the subject was then opened for
discussion and comment.
The NSA representative stated he had no objection
to the IC Staff initially participating in the NTISSC as an
observer, and the JCS representative agreed. The DIA and CIA
representatives were asked to provide comments and both agreed
with the suggestion. The Chairman concluded the discussion on
this subject by stating that without objection he would recommend
that the IC Staff provide a representative to the NTISSC to
participate initially as an observer.
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5. The Executive Secretary reviewed current issues
before the Committee for comment and vote. Particular mention
was made of the KGV-10/TSEC release request, specifically the
tardiness of some vote responses. At this point, some of the
representatives expressed concern at not having received the
correspondence. The importance of timely responses was stressed,
especially in cases of equipment release requests. The
Executive Secretary further stated he anticipated another six
issues requiring comments, and one issue requiring a vote
response to be forwarded to the Committee representatives in
the near future. These issues, listed below, will have a
30-day response requirement.
Directive on NTISS Issuance System
COMSEC Classification Instruction
DES Instruction
AUTOSEVOCOM Doctrine Instruction
COMSEC Equipment Instruction
KW-46 Fleet Broadcast Instruction, and
TSEC/KG-30 release request (for vote).
6. The next subject discussed by the Committee was the
National Policy on Application of Communications Security to
Civil (U.S. Government and Commercial) Space Systems. Formal
vote on this policy was delayed from the 8 November 1984 meeting
due to concern that the private sector had not been fully informed.
The FCC and NCS representatives provided feedback from the
private sector; the findings of both representatives was that
while the private sector does not disagree on the need to
provide satellite security, there still exists a need for more
definition and clarification of the policy. (The staff paper
prepared by FCC which summarizes the questions and issues raised
at the NIAC Communications Common Carrier Subcommittee meeting
on 29 January 1985, is enclosed. Copies of the vugraphs used in
the briefing presented by the NCS representative are available
upon request from the NTISSC Secretariat.)
Discussion followed as to how the Committee would best
resolve the questions and concerns put forth by the private
sector. The idea of forming a working group was viewed as being
too time-consuming and unproductive. The Commerce representative
suggested another approach to the private sector via letter.
It was further suggested by the NCS representative that NSA
undertake the necessary revision of the.policy, to which NSA
agreed. The Chairman stated that this issue would be brought up
again for vote at the 10 May NTISSC meeting.
The question of funding surfaced throughout the
discussion of this policy; the Chairman emphasized that funding
would not be provided by the Federal Government.
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7. A briefing was presented by the Chairman of the
Subcommittee on Telecommunications Security (STS) on The
Evaluation of the Security Status of National Telecommunications.
The STS Chairman stated that the report was still in a draft
status and was the result of the Subcommittee's meeting on
12 February. He expected to provide a finalized version of this
report by 25 February. He said that the report was approved by
the Subcommittee representatives, with an abstention by CIA and
a non-concurrence by OMB.
The briefing consisted of a summary of the STS report
(copies of this report were provided to the Committee representa-
tives prior to the meeting). The STS Chairman stated that as of
today our communications are still very vulnerable. During the
briefing the NTISSC Chairman questioned use of the phrase
"NO ACCEPTED DEFINITION OF A GOVERNMENT-WIDE COMMUNICATIONS
NETWORK", and the STS Chairman agreed to rephrase that term.
(Copies of the vugraphs used in the STS briefing are available
upon request from the NTISSC Secretariat.)
8. A briefing was also presented by the Chairman of the
Subcommittee on Automated Information Systems Security (SAISS) on
The First Annual Evaluation of the Status of Automated Information
Systems Security (AISS) in the U.S. Government. The SAISS
Chairman stated that this was the Subcommittee's final report,
which had been formally approved on 7 February. With the exception
of one abstention by NCS (because they had not received the report)
and one non-concurrence by OMB, all other Subcommittee representa-
tives concurred on the report.
This briefing also consisted of a summary of the SAISS
report (copies of this report were provided to all Committee
representatives prior to the meeting). In essence the report
stated that the status of automated information systems security
was poor and declining.
The SAISS Chairman also included the subject of the
interaction between the SAISS and the STS, upon which the NTISSC
Chairman remarked that the two Subcommittees appeared to be
working well together. (Copies of the vugraphs used in the SAISS
briefing are available upon request from the NTISSC Secretariat.)
At the conclusion of the SAISS briefing, the Chairman
stated that no further revisions were planned for these reports.
As soon as the final STS report was received the two reports
would be merged and published during the March timeframe.
9. In the discussion that followed the briefings presented
by the two Subcommittee Chairmen, the JCS representative
commented that the greatest problem was the volume of information
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STAT
being moved from one agency to another, and he felt that it
was volume which needed to be considered on both sides of the
assessment. There was much discussion regarding the securing
of communications. In particular, the NTISSC expressed concern
that the new upgrade of the FTS would not contain all the
necessary security requirements. The GSA representative stated
that every attempt had been made to incorporate these security
requirements into the GSA upgrade, but that cost was a major
consideration. She requested advice and assistance from the
Subcommittee Chairmen on how these requirements might best be
met, and the STS Chairman responded with an offer to assist.
epresentative provided a briefer,
to present the NSA views of how the
telecommunications systems security programming and budget
process/system would work. Only a portion of the actual briefing
had been presented when the Committee representatives began to
discuss the budget process and related problems.
Many present agreed that the existing budgeting process
was inconsistent. The FEMA representative commented that it was
difficult to project a five year plan, when in fact, OMB had
only approved funding every other year.
The NSA representative questioned the OMB representative
as to whether or not OMB was going to be able to bring the
budgeting together for COMSEC for the total Government. The OMB
representative's response was that he believed it would be
centralized, and stated that what OMB was requesting, was for
the data from all agencies and departments to be collected (in
terms of resources required to fix the critical areas), provide
a set list of those areas to be fixed, and submit a request
through the Steering Group and the National Manager.
11. The Chairman closed the meeting by saying he looked
forward to the next meeting of the NTISSC in May.
1 Enclosure
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NATIONAL TELECOMMUNICATIONS AND INFORMATION
SYSTEMS SECURITY COMMITTEE
February 15, 1985
Handout by Managing Director,
Federal Communications Commission
1. FCC Staff Paper
2. Minutes of NIAC Meeting
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? 1,
Attachment 1 - FCC Staff Paper
February 7, 1985
NUICNAL POLICY ON APPLICATION OF CCMMUNICATDONS
SECURITY TO COMMERCIAL SATELLITE TELEMETRY.
TRACKING AND CONTROL (nu)
1. yurpose
This paper summarizes issues raised at the NIAC Communications
Common Carrier Sub-Committee meeting on January 29, 1985 and
incorporates additional information obtained frau discussions with
sub-committee menbers and FCC statf after the meeting.
2. Need for Protection of 7T&C
a. There was no disagreement at the NIAC meeting on the need to
provide some measure of security for TT&C. Carriers contend that
they already provide some security measures. Further they
suggested several options to the government recommended technique
for provision of TT&C security which they believe may be much
less costly and equally effective in countering the threat.
Options suggested include: (1) continuous high powered uplink;
(2) an increase in command power threshold after satellite orbit
is established; (3) shaped TT&C antenna bean to reduce the proba-
bility of disruption from offshore points; and (4) intrusion
detection to permit inmediate activation of countermeasures.
b. while carriers apparently concur in the government's
objectives in this matter, they have serious concerns and nurnerous
unanswered questions regarding: the application of the proposed
national policy statement; what techniques might be approved by
the government for providing secure TT&C; and the relationship of
TT&C security to the much broader issue of total satellite systems
security, including other NSEP features that might be requested
by the government in the future.
3. Scope of Proposed Policy Statement
a. What is the intended scope of the proposed policy statement?
While the briefers professed that it would not preclude the
procurement of services by the government or government
contractors from commercial satellite systems before the effective
date of the policy, considerable further clarification is
required.
- Will the proposed policy preclude the procurement of services
from systems which were launched before the effective date if the
government determines that secure TT&C is required for a
particular application or progran?
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- Will the proposed policy apply to the procurement of all
satellite services by the government and goverment contractors
from systems which are launched after the effective date, or just
for those applications or programs where secure 'IT&C is a stated
requirenent?
- As a practical matter, will government contractors be forced
to procure satellite services only from government approved
systems even though only a portion of their business is with the
government?
b. Obviously, answers to these and related questions will greatly
affect the results of the proposed policy fran the government's
perspective as well as the carriers response' to the policy if
implemented. If broadly applied, the policy might cover a
significant portion of commercial satellite business and the
outcome might be quite different than if narrowly applied.
c. Certainly, the scope of policy application will
influence satellite carrier technical and business decisions which
in turn may affect their competitive position vis-a-vis other
satellite and terrestrial carriers. It is possible that the
policy might have anti-competitive consequences which would be
of concern to the FCC. This important issue is addressed in more
detail in the attached paper prepared by the Dcrnestic Facilities
Division of the Common Carrier Bureau.
d. Certainly, the scope of application will also impact the
effectiveness of the policy from the government's perspective.
If narrowly applied, some carriers may elect not to compete for
government business. This could have several undesirable con-
sequences including reduced competition, increased costs and
government dependence on one or a few systens to provide essential
communications. It is conceivable that the policy might produce a
result counter to the government objectives of flexibility,
redunaancy and interoperability. Concentration of government
traffic on one or two satellite systems might actually increase
the possibility of disruption.
4. Countermeasures and the Threat
a. TT&C countermeasures appear to be extremely threat dependent
both in terms of the nature of the threat and its duration.
Some countermeasures are very effective against one or more types
of threat and less eftective or not effective at all against
other types of threat. Not one technique discussed at the
meeting was effective against all types of threat to 'IT&C. For
example, continuous jamming can defeat crypto secure 'IT&C. And,
of course, physical destruction of critical satellite components
can render them inoperable regardless of measures taken to protect
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b. It appears that the carriers have already taken various
measures to protect against unauthorized access to the TTEic of
their satellite systems and have already established techniques
and procedures for regaining control should TT&C malfulction or an
unauthorized entity temporarily take control.
c. It appears that informed decisions by the government or
carriers with respect to security of TT&C cannot be made until
a more detailed analysis of threats and countermeasures is
completed. This analysis should include not only the recanmended
technique but options presented at the NIAC meeting as well as
techniques and procedures presently enplcyed by the =tiers.
5. Countermeasures and Cost
a. 'IT&C countermeasures are extremely cost variable, ranging fran
little or no additional cost to techniques requiring substantial
additional expenditures by the carriers. Increased costs may be
associated with design and construction as well as system
operation of both satellites and ground stations. Also,
weight/space considerations are particularly critical in satellite
design as they directly affect longevity, capacity and other
critical paraneters.
b. As mentioned above, the carriers have already taken some
measures to provide TT&C security and recovery capabilities in
the event of malfunction or unauthorized access. The question
is, how cost-eftective are these measures compared with other
possibilities and the technique recommended by the government.
Cost considerations aftect business decisions which in turn have
competitive marketplace implications. The briefers presented
virtually no information or analysis of any of these cost issues.
c. Again, it appears that an informed decision cannot be made on
this matter until a more detailed analysis is completed of various
countermeasures, including their costs.
6. Belationship of IT&C To Other Security Considerations
a. How do decisions regarding TT&C security relate to other
commercial satellite system security requirements? This is
another significant unanswered question which surfaced at the
NIAC meeting.
b. TT&C Security addresses only one type of threat to just one
component of a total satellite system. 'TT&C countermeasures
are designed principally to deny satellite access by unauthorized
entities or prevent unauthorized entities from denying control
to the system owner/operators. It does not address jamming of
control circuits, physical destruction or damage of vital
satellite components, security of ground stations and caranunica-
tions links, hardening, interoperability, and other security
concerns.
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C. It appears that the present government structure for dealing
with these issues is fragmented. The NTISSC charter is limited
to certain aspects of the overall problem. Other forms, such as
the NSTAC, are addressing equally if not more important satellite
system security issues. Further, consideration of sane of these
issues has been deferred.
d. The carriers have limited resources to spend on total
satellite system security and appear to be operating in a highly
competitive environment with other satellite and terrestrial
carriers. Accordingly, decisions regarding TT&C security (either
by the government with respect to procurement policy or by the
carriers themselves as they respond to the marketplace) should
not be made out of context. Absent a "systems" approach which
addresses the total problem and all viable solutions prior to the
issuance of the government TT&C procurement policy, the carriers
may make suboptirnum business and investment decisions. They may
take measures to guard against lager risk threats and protect less
vulnerable system components at the expense of protecting more
vulnerable system components against more likely threats. Large
investments in IT&C countermeasures in response to the issuance of
the proposed policy may preclude adequate investments in other
aspects of system security at a later date. In other words,
issuance of the procurement policy without further analysis might
contribute to reduced rather than enhanced overall satellite
system security. It is conceivable that a better overall
outcome might result from the government's perspective if the
policy statement is not issued. Further, as mentioned earlier,
the proposed policy may have unintended anti-competitive
consequences wnich would work counter to the governments overall
objectives of providing reliable and secure satellite communi-
cations.
7. Reliability of Recarmended Technique
a. At the NIAC meeting the carriers expressed concern about the
reliability of the recommended technique. Irrespective of the
other concerns expressed above, they are reluctant to proceed with
the substantial investment required to incorporate the reozatnended
technique into their satellite systems until its reliability is
adequately demonstrated. In other words, they don't want to buy
a "lock" when there is no assurance that the "key" will work. The
recommended technique has apparently not been tested in a space
environment. The briefers indicated it might be several years
betore tests are completed. This concern relates directly to the
issuance and effective dates of the policy.
8. Conclusions and Recamendations
- Finalization and/or promulgation of the proposed procurement
policy is premature absent extensive further study and analysis.
Further, it adopted, the policy should state its purpose, scope,
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and operation in the clearest possible terms in order to avoid
the confusion and concerns generated by the draft.
- The commercial satellite industry already uses a variety or
system design and operational techniqms to provide a measure of
TT&C security. They have suggested a number of other options.
Full consideration should be given to all of these, including the
government proposal, before the government policy statement is
finalized and promulgated.
- Most important, decisions regarding government 'IT&C procure-
ment policy should not be finalized absent a total satellite
systems security analysis. This analysis should include consi-
deration of all risks and threats including associated probabi-
lities in relation to all viable countermeasures together with
their effectiveness and costs.
- Accordingly, it is recommended that a government-industry
mechanism be established to conduct this system analysis and
submit findings and recommendations to appropriate government
authorities.
Prepared By: Alan R. McKie, Deputy Managing Director, in coordi-
nation with Thomas P. Stanley, Deputy Chief Scientist -Ccerations,
and James, R. Feegan, Chief, Domestic Facilities Division, Carmon
Carrier Bureau.
Attachment
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February 6, 1985
Domestic Facilities Division
Common Carrier Bureau
Concerns Regarding and Proposed Revision
to National Policy on Application of
Communications Security to Civil Space Stations.
The policy's overall approach is contractual: satellite carriers
wishing to do business with the government directly must secure the systems
over which they will carry government traffic, and those other companies
which seek government contracts must send their communications over secured
satellite systems. As a general proposition, the Commission does not
interfere in the marketplace bargaining that goes on between a customer,
such as the government, and service provider, such as a satellite carrier,
in contracting for telecommunications services.
In this instance, however, anticompetitive problems may arise
depending upon whether the policy, in its application to government
contractor use of satellite systems, covers government contractor use of
satellite services for all their business activities, or only use of such
services to conduct that portion of their business which relates to
performance of their government contracts. As currently drafted, the policy
does not make clear whether the broader or narrower interpretation is
intended, although its plain language makes it susceptible to the more
far-reaching interpretation. Yet, such an attempt to control the
telecommunications procurement choices of government contractors in their
activities that are outside the scope of their business or contracts with
the government, is problematic. While it may be an appropriate reflection
and exercise of market power for the government to dictate, through what is
in effect a government-vide procurement policy, the type of security its
contractors must provide with respect to the telecommunications activities
they undertake in connection with security related government business or
even government business generally, an effort to influence all government
contractor telecommunications practices in areas unrelated to government
contracts has the potential to distort the marketplace forces normally
governing the availability and selection of satellite systems and services.
The government would be using its power in a capacity far beyond that of an
ordinary communications service customer. By affecting the use of satellite
systems for the total volume of satellite traffic generated by all the
companies that do business with the government, the policy would have an
impact on the satellite industry far out of proportion to the government's
direct market power in this area. While we estimate that the government
uses less than 5% of the total capacity of satellites now in orbit, if the
policy were extended to all government contractor use of such systems for
any purposes, it would influence a much more substantial, if not major,
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segment of commercial satellite business. This effect may conflict with the
Commission's pro-competitive policies aimed at minimizing government
interference in marketplace structure and practices. Furthermore, while the
NTISSC has the authority to issue national policies applicable to and
binding upon the departments and agencies of the government, their authority
to similarly bind private entities through a government policy statement,
especially as to their non-government contract related activities, is
questionable. Would the obligations under the policy be imposed on the
contracting government agencies, the satellite carriers and/or the other
commercial entities contracting with the government? What would be the
relationship between these various obligations, and by what authority and
mechanism would they be enforced? These issues require clarification. The
policy would, in any event, be less troublesome to the FCC in its potential
to disrupt normal marketplace forces and relationships if its reach with
respect to government contractors were clearly limited to their use of
satellite systems for communications related to performance of their
government contracts alone. (See Attachment A for some suggested
alternative language.)
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1-.0.L.:1 Li i.C-11 ? '11/ LA al a lsj
SUMMARY MINUTES
FEDERAL COMMUNICATIONS COMMISSION
NATIONAL INDUSTRY ADVISORY COMMITTEE .
COMMON CARRIER COMMUNICATIONS SUBCOMMITTEE
Tuesday, January 29, 1985
AT&T Communications
Tenth Floor Conference Room
1120 - 20th Street, N. W.
Washington, D. C.
Chairman: John Boning
RCA Corporation
Public Notice of Meeting Appendix A
Attendance List Appendix B
Meeting Outline Appendix C
Draft of proposed National Policy on
Application of Communications Security to
Civil Space Systems Appendix D
Background Correspondence Appendix E
Optional Methods of Providing TT&C Security ? ^ Appendix F
The Chairman, Mr. Boning, opened the meeting at 9:45 A. M.
by thanking AT&T for the use of the excellent facility to
accommodate this NIAC Common Carrier Communications Subcom-
mittee meeting on the protection of telemetry, tracking and
control (TT&C) for commercial and civil satellites. He
mentioned the documents provided as handouts to all meeting
attendees (included as Appendices C, D and E of these minutes).
Mr. Boning cited some examples of verbage in the policy
that needed clarification, such as "civil satellites" and
"mission data."- These definitions were subsequently clarified
in the briefing by the National Security Agency (NSA).
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Mr. Boning provided a brief history of the National Security
Telecommunications Advisory Committee (NSTAC) Communications
Satellite Subcommittee (CSS) analysis wherein recommenda-
tions were made to protect the TT&C, to harden terrestrial
facilities against Electro-Magnetic Pulse (EMP), to enhance
physical security against terrorist attack, to provide a
capability for interoperability, to provide for protection
of traffic, and to enhance emergency planning and procedures.
Mr. Boning pointed out that if we can fully understand the
total threat to the satellite system, we can determine the
most practical solution to the problem. The total threat
is not just the TT&C problem. On 15 January SRI provided
a terrorist activities briefing by the FBI, FEMA, ERDA,
Treasury, and CIA. These federal agencies defined threats
that were very real and as significant as the TT&C threat.
Based on the above briefing, terrorism should be considered
as a new form of warfare perpetrated by three geheral
categories of terrorists, as follows:
o State supported terrorists
o Internal terrorists
o Crazies
The primary threat is from the state supported terrorists
who physically exist in this country. They are organized,
equipped, trained and capable. Many of them are identified
and are tracked by government agencies. The FBI defined
their usual targets, particularly in Central America, as
transportation, power, communications, finance and political
targets. Their modus operendi is never very clear. They .
are very clever, they use surprise to the maximum extent
and they desire spectacular results toward interrupting the
status quo of orderly government. They capitalize on fear.
Mr. Boning stated that the reason for the meeting today is
to discuss TT&C of commercial satellites and the protection
thereof. There are several options to provide protection;
each option has its drawbacks and all are scenario dependent.
Even though this particular meeting is on TT&C, the carrier
must also address all of the threats. The satellite carriers
must be very careful in protecting against these threats lest
their costs escalate to the point that their business picture
is so burdened by protection systems that they can no longer
be competitive. In such an event the terrorists would have
won without ever challenging the system.
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3
Mr. McKie of the Federal Communications Commission (FCC)
stated that the meeting was called to provide information
for Mr. Edward J. Minkel, the FCC Managing Director, prior
to his participation in an upcoming meeting of the National
Telecommunications and Information Systems Security
Committee (NTISSC).
Mr. Boning introduced Mr. Noell Matchett of NSA who initiated
a classified briefing on the threat to commercial satellite
TT&C.
In an unclassified portion of the briefing NSA agreed to
provide a high quality algorithm that can be embedded in the
TT&C package of the satellite by the satellite manufacturers.
The overall system would be unclassified but the computer
chips would be controlled. With the agreement of the
carriers NSA will provide counsel, expertise, evaluation and
endorsement of the TT&C incorporated into commercial system.
The system will contain characteristics for interoperability.
Radiation hardening of the subsystem is being developed but
hardening is not required.
Five years after the adoption of a national policy on TT&C
government Requests for Proposals (RFP's) may include a
specification for protected TT&C.
NSA concluded that TT&C incorporation makes good sense to
the government. NSA counsel, advice and guidance is
available and all potential protection techniques will be
considered.
Following the NSA briefing the subject was opened for
questions and general discussion.
Several questions were asked involving the definition'of the
term, "civil satellite." These were defined as applications
type satellites that generate on board information. METSAT
and LANDSAT are in the civil satellite category.
Another series of questions involved the term, "mission
data." This was defined as the data from civil satellites
that develop on board information. There is no mission data
on commercial satellites. This point is very significant
because several of the carriers had interpreted "mission
data" as commercial satellite through-put. If they became
responsible for the protection of that data they would face
a severe financial burden.
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Another question was, "Why is the threat limited to accessing
the satellite rather than destroying the satellite by lasers
or high powered signals?" One answer was that the satellite
could be held for ransom.
A question was posed based on the SRI briefing wherein the
FBI defined threats against terrestrial facilities. Since
the carriers must address such threats as well as inter-
operability, EMP protection, and command survivability, the
question asked if anybody is looking at the total threat
package and making a systems analysis and cost estimate of
all the protection needed. The answer indicated that this
is an NSTAC problem but that NSTAC has not yet addressed it.
Further, the stated government strategy included a presumption
that the free market will allow carriers to recoup cost on a
competive basis and that there may even be some insurance
savings. Both of these statements were disputed by several
carriers. Another point introduced was that, based on a survey,
commercial entities were not interested in traffic protection.
Nevertheless, costs resulting from protection systems will be
passed along to the public.
Carriers reiterated the related point that as protection
requirements increase, so does the cost of service. In the
meantime, terrestrial point-to-point traffic costs are going
down. The Chairman stated the carriers do not dispute the
fact that encryption Of TT&C is a good protection against the
threat described by NSA but that the FBI has drawn up just as
realistic a threat scenario which may include the destruction
of satellites and terrestrial communication systems for which
encryption provides no protection. The carriers expressed
concern about how all of their protection efforts will be paid
for. One of the carriers proposed tax incentives to help
offset some of the more significant costs.
The Chairman interrupted the discussion in the interest of
time and requested that a TT&C engineer describe several
options to providing protected TT&C.
Mr. Lewin, RCA Manager of Satellite Operations, provided
four options, each involving a different scenario. One
option is a continuous high powered uplink carrier (Ku band)
that would effectively jam the TT&C receiver to preclude
accessing the system with present state of the art hardware.
A second option is to raise the command threshold level on
the satellite once orbit is established. A third option
exists to shape the beam of the TT&C antenna to minimize
its coverage. A fourth option is to incorporate intrusion
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5
detection to provide a very rapid indication that the
satellite is being accessed by outside parties; this system
is installed in some satellites now and presumes an override
capability at the TT&C station. A more complete description
of the options discussed by Mr. Lewin are contained in
Appendix F.
A carrier questioned whether or not the grandfathered
systems (within five years of a National Security Policy on
TT&C) would be ignored in the future in favor of the newer
protected systems. The answer from a Defense Communications
Agency (DCA) spokesman was that an RFP can state that there
is a requirement for protection. In other words, there is
nothing to stop a government agency from specifying TT&C
protection before the grandfather period ends.
The open discussion ended and the Chairman summarized
proposed submission of conclusions to the NIAC Long Range
Planing Committee and the FCC as follows:
o All solutions offered for the protection
of TT&C are scenario dependent. '
o There are many security problems other
than TT&C, including destruction of the
satellite and/or ground facilities, and
EMP considerations.
o Costs of total security will significantly
affect the competitive position of satellite
carriers.
An overall conclusion to be drawn from the meeting is that
there is a critical need to take a systems approach to the
protection of satellite systems and communications resources
in general prior to establishing a national policy om such a
narrow aspect as TT&C of satellite communications. The
terrorist threat is real and can be anticipated when it is
politically expedient for the terrorists to attack.
The meeting was adjourned at 12:02 P. M.
Herbert J. Neumann
Executive Secretary, NIAC
(
Johti Boning
Chairman, Common Carri
Communications Subc ittee
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APPENDIX A
PUBLIC NOTICE
FEDERAL COMMUNICATIONS COMMISSION
1919 M STREET N.W.
WASHINGTON, D.C. 20554
1795
News media information 202/254-7674.
Recorded listing of releases and texts 202/632-0002.
FCC 85-1
35452
January 8, 1985
NATIONAL INDUSTRY ADVISORY COMMITTEE
COMMON CARRIER COMMUNICATIONS SUBCOMMITTEE
NOTICE OF MEETING
Pursuant to the provisions of Public Law 92-463, notice is
hereby given of a closed meeting of the Common Carrier
Communications Subcommittee of the National Industry
Advisory Committee (NIAC) to be held Tuesday, January 29,
1985. This meeting is closed to the public under authority
of Section 10(d) of the Federal Advisory Committee Act
(P. L. 92-463, as amended). The Subcommittee will meet at
9:30 A. M. at AT&T Communications, 1120 - 20th Street, N. W.
Washington, D. C. 20036, North Tower.
PURPOSE: Classified briefing concerning satellite
communications matters.
AGENDA : As follows:
1. Opening remarks by Chairman.
2. Briefing and discussion.
3. Adjournment.
For more information about the meeting the NIAC Executive
Secretary in the FCC Emergency Communications Division may
be contacted at [phone].
Action by the Commission January 4, 1985. Commissioners
Fowler (Chairman), Quello, Dawson, Rivera and Patrick.
?
- FCC -
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APPENDIX B
Page 1
Attendance List
NIAC Common Carrier Communications Subcommittee
Chairman
John Boning
NIAC Members
William Jack
Charles Meizner
James Oref ice
Colemen Guthrie
George Tellmann, Jr.
Jeff Kushan
Lowell Thomas
Angelo Nicosia
Marianne Swindler
Michael Shaw
John Dunlop
Other Industry
Stuart Meister
Robert Yamazaki
Robert Bradshaw
Troy Ellington
G. Jay Nelson
Richard Heitman
Jerold Jacaruso
Al Prekeris
Jacob Lewin
Charles Somerville
Donald Jansky
Federal Government
Karl Brimmer
Fred Goldsmith
James Keegan
Kevin Kelley
Michael Marcus
Alan McKie
Herbert Neumann
Jack Richards
Raymond Seddon
Anne Siegel
Thomas Stanley
January 29, 1985
RCA Consultant
AT&T Communications
AT&T Communications
AT&T Communications
COMSAT General
COMSAT
GTE Sprint
GTE
ITT
ITT
MCI
TRT
AMSAT
COMSAT
GTE
GTE
GTE Sprint
ITT
ITT
ITT
RCA Americom
TRT
TRT Consultant
FCC
FCC
FCC
FCC
FCC
FCC
FCC
FCC
FCC
FCC
FCC
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1STAT
APPENDIX B
Page 2
Attendance List (Continued)
NIAC Common Carrier Communications Subcommittee
January 29, 1985
Federal Government (Continued)
Capt. David Brown
J. Randolph MacPherson
Benham Morriss
George Silbermann
Milton Weiner
NCS
NCS
NCS
NCS
NCS
Arthur Altenburg
NTIA
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APPENDIX C
lational Industry Advisory Committee
Common Carrier Communications Subcommittee
Meetinz Outline
January 29, 1985
Background and Objective:
o The Government is formulating a national policy regarding the
procurement of commercial satellite systems and services by Federal
agencies and government contractors. This policy will address
government requirements for communications security with respect to
both message traffic and telemetry, tracking and control (TT&C).
o The NIAC Common Carrier Communications Subcommittee has been convened
by the FCC to provide a forum for the presentation and discussion of
the potential threat to TT&C of commercial satellite systems, and the
various measures which might be employed by the owners and operators of
these systems in order to provide protection against this threat when
required by the government. (The meeting will not address security of
satellite message traffic.)
o The government seeks information on the full range of options available,
the merits and demerits of each, their costs, and any other information
which may be useful in finalizing the proposed national procurement
policy.
o Additional government-industry meetings and discussions may be required
to conclude technical evaluations of options identified at the meeting.
Order of Discussion:
1. Threat Briefing
2. One Proposed Solution to the Threat
3. Clarification of Draft Policy Statement
4. Identification and Discussion of Other Options to Counter the Threat
5. Summation
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NATIONAL POLICY
ON
APPLICATION OF COMMUNICATIONS SECURITY TO CIVIL
(U.S. GOVERNMENT AND COMMERCIAL) SPACE SYSTEMS
SECTION I - POLICY
1. Government classified and Government or Government
contractor national security-related information transmitted
over satellite circuits shall be protected by approved
techniques from exploitation by unauthorized intercept.
2. Government or Government contractor use of U.S. civil
and commercial satellites launched five years from the date of
this policy shall be limited to space systems using approved
techniques necessary to protect the essential elements of
telemetry, tracking and control (TTiC) and mission data.
'SECTION II- EXCEPTIONS
3. Exceptions to this policy may be granted by the NTISSC
in consultation with Federal departments and agencies as well as
the private sector.
SECTION III - DEFINITIONS
4. Space systems consist of the spacecraft or satellite,
command ground station, data acquisition stations,
telecommunications, TT&C, and mission data functions.
5. Mission data is transmitted by the spacecraft to
accomplish its operating objectives. Protected essential
elements are Iliose?fun-ctions of TTINC which would deny
unauthorized control of the space system.
SECTION iv - sEADs OF DEPARTMENTS
6. The Director, National Security Agency, in
coordination with other departments or agencies as appropriate,
shall assess space systems telecommunications, TT4C, and mission
data functions to determine their vulnerability to unauthorized
use and provide approved protection techniques and guidance.
7. Nothing in this policy shall relieve the heads of
Federal departments and agencies of their authority and
responsibility for executing other measures to assure the
adequate protection of their telecommunications.
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November 27, 1984
MEMORANDUM
GTE Service Corporation
1120 Connecticut Avenue N.W.
Washington, D.C.20036.
[phone]
TO: Members, long Range Planning Committee,
National Industry Advisory Committee
SUBJECT: National Policy on Applications of Commumicastions
Security to Civil (U.S. Government and Commercial)
Space Systems
The N1AC Long Range Planning Committee hal been asked by-_the FCC
to comment on a draft "National Policy on Applications of
Communications Security to Civil (U.S. Government and Commercial)
Space Systems."
The cover letter and draft policy requesting our assistance from
Ed Minkel of the FCC is attached. An answer from the LRPC is
expected before the Holidays.
Please provide your comments to me at 1120 Connecticut Avenue,
.N.W., Suite 900, by December 6, 1984. We will consolidate your
comments and coordinate with each of you before an answer, is
provided to the FCC. -
Since Commissioner Dawson and Ed Minkel are anxious to receive
our comments, I would prefer not to convene a formal meeting of
the LRPC, but stand ready to do so if necessary.
Thank you for your cooperation.
Sincerely,
C. J. Mclean
Vice President
Government Communications
CJM:mhf
Attachment
cc: Chairman Mark Fowler Honorable David Markey
Commissioner Mimi Weyforth Dawson Lt. Gen. Winston Powers
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FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON. D.C. tOSSII
November 21, 1984
ON *MT 111011, TO.
Cyrus J. McLean
Vice President ? Government Communications
GTE Service Corporation
Stamford Forum, Stamford Conn. 06904
Dear Mr. McLean:
I am writing to you in your capacity as Chairman of the Long Range
Planning Committee of the Commission's National Industry Advisory Committee.
National Security Decision Directive 145 (NSDD 145), "National Policy on
Telecommunications and Automated Information Systems Security," signed by
the President on September 17, 1984, establishes initial objectives,
policies, and an organizational structure for national activities aimed at
safeguarding from hostile exploitation systems which process or communicate
sensitive information. That Directive established, in place of the former
National Communications Security Committee (NCSC), the National
Telecommunications and Information Systems Security Committee (NTISSC), a
working level interagency group operating under the direction of a senior
level steering group, to consider technical matters and develop operating
policies as necessary to implement the provisions of ESDD 145. The
Commission participates in the NTISSC as an observer. As part of its
effort, the NTISSC has prepared a draft "National Policy on Application of
Communications Security to Civil (17.S. Government and Commercial) Space
Systems." That policy, a copy of which is attached, would limit government
and government contractor use of space systems to those which use "approved
techniques" to protect the telemetry, tracking and control elements that are
essential to control of the space system.
Because of the Commission's regulatory role in licensing domestic
communications satellites, we have a responsibility to assess the impact
of the NTISSC satellite security policy on the commericil satellite
industry. One of NIAC's roles has been to advise the Commission on NSEP
matters, and once again we look to your group for assistance. We request
that you review the draft National Policy and provide the Commission with
informal comments reflecting the consensus of your committee members by the
end of the year. NIAC's evalvation of this important facet of the
government's National Security and Emergency Preparedness efforts will
enable the Commission to most effectively fulfill its regulatory
responsibilities. Because the policy is in draft form, we ask that its
circulation be limited to your committee members.
NIAC's work on NSEP issues have been of great value to the
Commission in the past, and on behalf of the Commission I thank you for your
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2
efforts in tbis vital area. We look forward to receiving your comments and
to our continued cooperation.
Sincerely.
WGtj 1$n) 5
Managing Director
Enclosure
cc: Chairman Mark Fowler
Ccrmz is sioner Mini Wey forth Day eon
Honorable David Markey
U. Gen. Winston Powers
1K\ bAjt.
.A.NpA ? S21/4/1 MOOLL40.
Ax .
tyAA. &t,e_i_z.v.L.t ?
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RATIONAL POLICY
ON
APPLICATION OF COMMUNICATIONS SECURITY TO CIVIL
(U.S. GOVERNMENT AND COMMERCIAL) SPACE SYSTEMS
SECTION I - POLICY
1. Government classified and Government or Government
contractor national security-related information transmitted
over satellite circuits shall be protected by approved
techniques from exploitation by unauthorized intercept.
2. Government or Government contractor use of U.S. civil
and commercial satellites launched five years from the date of
this policy shall be limited to space iystems using approved
techniques necessary to protect the essential elements of
telemetry, tracking and control (TT&C) and mission data.
SECTION II- EXCEPTIONS
3. Exceptions to this policy may be granted by the NTISSC
in consultation with Federal departments and agencies as well as
the private sector.
SECTION III - DEFINITIONS
4. Space systems consist of the spacecraft or satellite,
command ground station", data acquisition stations,
telecommunications, TT&C, and mission data functions.
5. Mission data is transmitted by the spacecraft to
accomplish its operating objectives. Protected essential
elements are those functions of TT&C which would deny
unauthorized control of the space system.
SECTION IV - BEADS OF DEPARTMENTS'
6. The Director, National Security Agency, in
coordination with other departments or agencies as appropriate,
shall assess space systems telecommunications, TT&C, and mission
data functions to determine their vulnerability to unauthorized
use and provide approved protection techniques and guidance.
7. Nothing in this-policy shall relieve the heads of
Federal departments and agencies of their authority and
responsibility for executing other measures to assure the
adequate protection of their telecommunications.
iC
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GTE Service Corporation
1120 Connecticut Avenue N.W.
Washington, D.C. 20036
[phone]
December 19, 1984
Mr. Edward J. Minkel
Managing Director
Federal Communications Commission
1919 M Street, N.W.
Room 852
Washington, D.C. 20554
Dear Mr. Hinkel:
This responds to your letter of 21 November 1984, in which you ask for the
National Industry Advisory Committee (NIAC) to comment on the draft executive
branch policy on xhe "Application of Communication Security to Civil (U.S.
Government and Commercial) Space Systems." I have asked the members of the
NIAC Long Range Planning -Committee for their thoughts on this matter.
Enclosed are the comments from a number of the members. As you can see the
draft policy has raised a number of questions and concerns. Some of the areas
in which there, is uncertainty include:
' Ambiguity over what is intended by the policy;
' Appreciation for the nature of the threat;
' Clarification over the type of technique which may be used to protect
commercial communications satellites.
As should be apparent, the NIAC membership is not now in a position to endorse
this proposed policy. Many of the carriers' concerns could be aleviated if
they receive information which would clarify the points raised. We recommend
that this matter be referred to the Common Carrier Subcommittee for a
A part ol GTE Corporation
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classified briefing during January. The Common Carrier Subcommitte would then
be in a position to make recommendations to the FCC.
Thank you for the chance to comment on this policy.
Sincerely,
?
C. . McLean .
Chairman, Long Range Planning Committee
National Industry Advisory Committee
CJM:dmp
Enclosures
cc:
Chariman Mark Fowler, FCC
Commissioner Mimi Weyforth Dawson, FCC
Honorable David Markey, NTIA
Lt. Gen. Winston Powers, NCS
Hubert J. Neumann, FCC
Long Range Planning Committee Members:
Robert F. Allnut, COMSAT Corp.
John Boning, RCA American Communications, Inc.
Eugene S. Cowen, American Broadcasting Company
Mark E. Crosby, Special Industrial Radio Service Association, Inc.
Charles Dorian, The American Radio Relay League, Inc.
Wallace Dunlap, Westinghouse Broadcasting Company
John Dunlop, TRT Telecommunications Corporation
Charles R. Dunn, Commercial Radio & Electronics
Eugene Eidenberg, MCI Telecommunications Corporation
Edward O. Fritts, National Association of Broadcasters
Joseph J. Gancie, ITT World Communications, Inc.
Arthur A. Garman, Western Union Telegraph Company
Robert E. Cradle, AT&T Technology Systems
Wayne Green, Wayne Green Enterprises, Inc.
Jerry M. Haleva, California Legislature
Robert D. Hynes, Jr., National Broadcasting Company, Inc.
Robert W. Kinzie, COMSAT General Corporation
Marvin W. Konow, Bell Communications Research, Inc.
E. J. Rushan, GTE Sprint Communications Corporation
C. Travis Marshall, Motorola, Inc.
Henry W. Meetze, Railing Corporation
Ron Nessen, Mutual Broadcasting System, Inc.
Richard O. Newman, Public Service Company of Oklahoma
Morgan E. O'Brien, Lukas, O'Brien and Raiser
Samuel F. Shawhan, GTE Corporation
Hillyer S. Smith, Jr., Aeronautical Radio, Inc.
Robert H. Snedaker, Jr., United Telephone System, Inc.
John B. Summers, National Association of Broadcasters
Roy M. Teel, Jr., MSI Communications, Inc.
Donald D. Wear, Jr., CBS, Inc.
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To:
From:
Date:
Subject:
Inter-Office Memo
Lowell Thomas
Leslie A. Taylor, GTE Spacenet Corporation
December 19, 1984
GTE Spacenet Corporation
Proposed National Policy on Government or Government Contractor Use of
U.S. Civil and Commercial Satellites
The following are the concerns of GTE Spacenet relative to the NSTAC
proposal on the Draft National Policy on Application of Communications
Security to Civil (U.S. Government) and Commercial Space Systems.
1. The purpose(s) of the proposed policy needs clarification.
(a) is the purpose to provide protection to government classified
traffic carried over commercial systems?
(b) is the purpose to prevent access by unauthorized persons to the
facilities of commercial space system operators?
(c) is the purpose to ensure that protection is available over
commercial systems in the event the government needs to utilize
such systems in a national emergency?
(d) is the purpose all of the above?
2. What is the definition of "approved techniques?" Will commercially
available encryption equipment be adequate, or will NSA equipment or
NSA approved equipment be required? The costs and feasibility of
various requirements could vary greatly.
3. The grandfather clause may not adequately protect companies such as
GTE which is now deploying its satellite system. The thrust of the
policy appears to indicate a strong preference for protection and
this is likely to appear in RFPs, thereby excluding GTE from such
government business. There are certain other companies which would
be in a strong position with such a policy in place.
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Proposed National Policy
December 19, 1984
Page two
4. The cost/benefit trade-off for the private satellite operator is
really unknown, particularly because of the uncertainty as to what
equipment would be required, and if any government classified
business would ultimately be obtained, even if systems are
retrofitted.
5. Are there comparable requirements imposed or proposed for terrestrial
communications systems?
6. Under Definitions, what does "data acquisition stations" mean? Does
it mean earth stations, transmit/receive?
Conclusion: While GTE Spacenet can understand the government's desire to
have commercial operators bear the expense of installing
protection devices on space systems, the draft policy is so
vague .that it provides insufficient guidance as to how an
operator can quantify the costs of so doing, the benefits of
so doing, or even if the installation of protection devices
would satisfy the government's requirements..
Please let us know it we can be of additional assistance in this matter.
Leslie A. Taylor
Director, Regulatory. Affairs
1259P
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November 29, 1984
Nr. C.J. Mclean
Vice President - Government Communications
GTE Service Corporation
1120 Connecticut Avenue, N.W.
Suite 900
Washington, D.C. 20036
Boll
Communications
Research Inc.
Dear John,
This is in response to your November 27, 1984 memorandum concerning the
proposed "National Policy on Applications of Communications Security to Civil
(U.S. Government and Commercial) Space Systems".
As you know, neither Bell Communications Research nor the Bell Operating
Companies that we support are in any way involved in satellite communications
systems. For that reason, I do not feel it would be appropriate for us to
comment on the proposal.
I look forward to working with you on future issues where our input could be
helpful.
Sincerely,
? LA) N? trse%4N--.3
M.W. Konow
Assistant Vice President
National Security and Emergency Preparedness
MWK-plb
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Lill LI
western union
A. A. GARMAN
VICE PRESCIENT APO GENERAL MANAMA
Mr. C.J. McLean
Vice President
GTE Service Corporation
1120 Connecticut Avenue N.W.
Washington D. . 20036
Dear Jo
December 4, 1984
1 e reviewed the draft National Policy on Application of Communications Security
to Civil (U.S. Government and Commercial) Space Systems attached to your letter dated
November 27, 1984.
The wording of Section I - Policy, and Section III - Definitions, is unclear and is likely
to lead to confusion. Section 1, Paragraph 2 introduces a new element, "mission data". Section
III states that "mission data is transmitted by the spacecraft". Since Section III, Paragraph 4
differentiates between spacecraft and satellites, I assume spacecraft are shuttles or space
probes or the like. Since we service suppliers only deal in satellites I do not understand what
satellite-originated information is being referred to which would need to be protected. This
should be clarified.
Section I - Policy, Paragraph 1 deals with information transmitted over satellite
circuits and this is certainly the prerogative of the Government user. This can be implemented
at any time and is basically a function of cost.
Section 1, Paragraph 2 deals with protection of the TT&C which is understandable. It is
not clear that such a mandate is in the best interest of the country (all suppliets of TT&C
' must be protected for all launches after five years from the date of the policy). The obvious
individual advantages of satellite protection must be weighed against the technical problems
posed in the face of solving the satellite interoperability question being addressed by NSTAC.
Clearly, this issue should be thoroughly discussed with NSTAC.
If I may contribute further, please do not hesitate to call me.
Sincerely,
iles,6?$11A7thuilr A. Garman
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RCA, Arne,.cen Communications Inc I 400 College liOa 0 Lest riinGgiuri
FAX [phone] I Icel. 244010
Government Services
Mr. C. J. McLean
Vice President GTE
1120 Connecticut Ave.. N.W.
Washington, DC 20036
Reil
Dear John: November 29, 1984
Reference is made to your memo dated 27 November 1984, Subject: National
Policy on Applications of Communications Security to Civil (U.S.
Government and Commercial) Space Systems.
The enclosed paper lists the problems and questions generated by each
paragraph of the proposed national policy.
We find the policy paper severely lacking in definition and intent. I
recommend that we convene a closed session of the Common Carrier
Subcommittee or an informal gathering of the same. group with
representatives of RUA to clarify what the government wants and what can
be done for the government with and without support funding.
Regards,
e41,/
n Boning
RCA Member NIAC
JB:glt
Enclosure
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COMMENTS ON PROPOSED NATIONAL POLICY
The following comments on the draft National Policy are provided for each
paragraph contained therein.
Section I - Policy Paragr!ph 1
'Government classified and Government or Government contractor national
security - related information transmitted over satellite circuits hall
be protected by approved techniques from exploitation by unauthorized
Intercept.'
Comment
To the best of our knowledge and belief, this policy has been in effect
for an extended period. The Government determines the classification of
information and is responsible for its protection. For the purposes of
transmitting this information if it is classified, the government
encrypts the data and provides an encrypted bit stream to the carrier who
delivers the encrypted data to the premises of the receiving user. The
receiving user decrypts the bit stream. Encryption equipment is not
commonly provided to the carrier. The government is responsible for
using government approved encryption techniques.
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Section I - Policy Paragraph 2
'The government or government contractors use of U.S. civil and
commercial satellites launched five years from the date of this policy
should be limited to space systems using approved techniques necessary to
protect the essential elements of telemetry tracking and control (TT&C)
and mission data.'
Comment
This paragraph is not entirely clear in the following areas.
a. What is meant by a civil satellite and how does it differ from a
commercial satellite?
b. What is the date of the policy - when does the 5 year time period
start? Depending on when an 'approved" system will be available, the
five years may not be realistic.
c. It is assumed from reviewing paragraph 6 below that the approving
authority of techniques used in protection of ITU is NSA. This
should be stated. Also, a departmental contact point needs to be
established. If any other agencies or departments are involved in
the approval, they should be listed to provide a definitive
contact(s) for carriers trying to determine their appropriate action
and when it is satisfactorily completed.
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d. The term 'mission data' may be interpreted several ways. Since the
mission of the satellite is to relay data between terrestrial points,
it is assumed that this policy is directed toward specific circuits
that need to be protected. Is it the intent of this policy to have
the carrier responsible for encrypting the circuits to be protected?
Section II - Exceptions Paragraph 3
'Exceptions to this policy may be granted by the KTISSC in consultation
with Federal departments and agencies as well as the private sector.'
Comment
Since RCA American Communications,, Inc. has not been provided with a copy
of NSDD 145, it is not clear as to who is the approving authority for
exceptions.
Section III - Definitions Paragraph 4
'Space systems consist of spacecraft or satellites, command ground
station, data acquisition stations, telecommunications, TUC, and mission
data functions."
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Comment
See comment in paragraph (d) under Policy Paragraph 2. 'Mission data
functions' is ambiguous.
Section III - Definitions Paragraph 5
?Mission data is transmitted by the spacecraft to accomplish its
operating objectives. Protected essential elements are those function of
TT&C which would deny unauthorized control of the space system.'
See above comments on mission data. This definition does not clearly
define what is meant by the term mission data. The spacecraft does not
initiate transmission.
Section IV - Heads of Department Paragraph 6
'The Director, National Security Agency, in coordination with other
departments or agencies as appropriate, shall assess space systems
telecommunications, TT&C, and mission data functions to determine their
vulnerability to unauthorized use and provide approved protection
techniques and guidance.'
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This activity, to be successful, should have the full participation of
each carrier concerned since each carrier resources have different
characteristics.
Section IV - Heads of Departments Paragraph 7
'Nothing in this policy shall relieve the heads of Federal departments
and agencies of their responsibility and authority for executing other
measures to assure the adequate protection of their telecommunications.'
No Comment
General Conrnents and Questions
a. Encrypted TUC links are vulnerable to jamming - extended jamming can
cause a loss of control of the satellite.
b. Does this policy directive provide for monies necessary for TUC
encryption, software modification, security measures and physical
TUC site security, and training?
c. Does this policy directive contemplate placing the responsibility for
broad band traffic encryption on the carrier?
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d. Can paragraph 6 be interpreted to mean that NSA will pay for expenses
associated with encryption?
e. If the carriers are to pay for the equipment associated with this
policy, how would the government address the problem of competition
with terrestrial systems who presumably handle traffic in the time
proven manner and do not have the financial burden of encryption?
f. Does the proposed policy contemplate modifying all satellites capable
of handling government traffic whether or not they are used for that
purpose (i.e. an exclusively all video distribution satellite).
9.
Is the government aware that a hi-powered uplink carrier that
saturates the TT&C receiver, can provide more protection against a
conus originated signal than an encrypted uplink?
h. There are more credible threats than acquiring TT&C such as burning
out the front ends on the receivers or burning out the earth sensors.
I. I suggest that this policy be discussed among the carriers and the
drafters of this policy paper and NSDD 145. It may be more easily
handled with the NIAC Commission Carrier Committee rather then the
entire Long Range Planning Committee. Until some of the above
questions are answered, RCA cannot provide a position on this
ambiguous document.
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c
A Subsidiory of the
Association of
American Rollroods
Henry W. Meet.)
President
Mr. C. J. McLean
Vice President
Government Communications
GTE Service Corporation
1120 Connecticut Ave., NW
Washington, DC 20036
Dear Mr. McLean:
November 30, 1984
Reference, your memo of November 27, 1984, regarding National
Policy on Applications of Communications Security to Civil (US
Government and Commercial) Space Systems. I raise a concern
regarding execution of that policy by the National Security
Agency, but not with the policy itself which is quite broad. Spe-
cifically, I believe the commercial sector should be assured that
the 'approved protection techniques' provided by NSA will neither
inhibit the commercial use of satellite communications nor the
exploitation of that technology. Thank you for the opportunity to
comment on the draft policy.
Sincerely,
RAILINC CORPORATION ? 1920 L Street, N.W. ? Washington, D.C. 20036
? 202/835-9400
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e!4:1 COMSAT
COMMUNICATIONS
SATELLITE
CORPORATION
Robert F. ADnott
Vu President
Gownsman( Adios
December 13, 1984
Mr. C. J. McLean
Vice President
Government Communications
GTE Service Corporation
1120 Connecticut Ave., SW
Washington, DC 20036
Dear Mr. McLean:
This responds to your memorandum of November 27, 1984, to the Members
of the Long Range Planning Committee of NIAC. On behalf of COMSAT, I want
to thank you for the opportunity to provide comments on what we deem as an
important evolving national policy.
Last year, the National Satellite Telecommunications Advisory Commis-
sion (NSTAC) recommended that operators of commercial communications satel-
lites should (a) in the short term, provide some method of command link
protection; and (b) in the longer term develop, with the government, a com-
mand link encryption standard. NSTAC also reviewed telemetry encryption
and decided that this was not required to protect satellites against unautho-
rized conmand access.
We agree with the NSTACconclusions.
With regard to the five-year grace period proposed by the policy, we
feel that this is a reasonable period and would urge its retention in any
policy that is finally adopted. We would suggest that a useful next step
should be working level meetings between representatives of the government
and the industry--both manufacturers and satellite owners?to discuss' the
means of implementing the policy in detail. In this regard, we believe that
the government should set standards for command link protection. rather than
issuing detailed specifications for encryption equipment or other means of
protection.
Robert F. Allnutt
950 Ltrdant Plaza SW
Washington. DC 20024
TeImhof* 202.8634313
Teks WQ66%
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CON
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SENATOR WILLIAM CAMPBELL
CHMRMAN
December 5, 1984
Mr. C.J. McLean
Vice President, Government
Communications
GTE Service Corporation
1120 Connecticut Avenue, N.W.
Washington, D.C. 20036
Dear Mr. McLean:
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Upon reviewing the draft 'National Policy on
Telecommunications and Automated Information
Systems Security, I concur with the need to
safeguard from hostile exploitation those
telecommunications systems that process sensitive
information. It appears that the identified
objectives and policies for developing the
necessary safeguard measures could be successfully
implemented given the proposed organizational
structure.
My only concern is in regard to the role and input
of the Federal Communications Commission in this
project. Since the FCC is responsible for licensing
and regulating domestic telecommunications systems,
I firmly believe that those individuals involved in
the decision making process should consult with the
Commission. I am confident that a cooperative
arrangement can be established to bring that about.
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Mr. C.J. McLean
December 5, 1984
Page two
Thank you for allowing me the opportunity to comment on this
draft policy. If I can be of any assistance, please contact me at
your convenience.
cerel
/ 17,ERRY M. EALEVA
B if
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MEMO TO THE COMMON CARRIER SUB COMMITTEE
Re: "The National Policy On Application of Communications
Security TO Civil Space Systems"
The Common Carrier Sub Committee has been asked to address
the above national policy for adequacy and acceptability to the
Common Carriers. A survey was conducted by the Long Range
Planning Committee and the concensus was that the policy was
ambiguous in several important areas. Some terms were not
clear. The intent of the government as to how the services are
to be provided is not clear. The threat is not well defined.
Section I of the Policy paragraph 2 Indicates two needs:
(1) Protection for classified government communications.
(2) A protection of presumably unclassified but sensitive
government contractor security related information.
Protection of the communication of classified government
information in accordance with existirig policy, is the
responsibility of the originator of the transmission. This is
usually done by providing the carrier with an encrypted bit
stream that is transmitted to the receiving agent who in turn
decrypts the signal. This represents no problem to the carriers
and has been a standard operation for some years.
Protection of the unclassified data Is less clear. Is the
protection DES or KG equipment? Is the protection circuit by
circuit or by bulk encryption. How Is analog handled? The
circuit by circuit protection is not a problem if the originator
provides a protected bit stream to the carriers. However, if the
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carrier is to provide bulk encryption as a service, this is a
problem that warrants considerable discussion and definition.
Paragraph 2 of Section 1 defines a need to protect "The
essential elements of Tracking Telementry and Control (TT&C) and
mission data. Definition Is required on the word "protect" and
the words "mission data." Is the protection system defined by
the carrier at the government? If the government defines a
system that places a financial burden on the carriers, does the
government assume financial responsibility?
Much of the system definition problem Is a lack of a clear
Threat analysis that defines the problem to be solved. NSDD 145
Indicates the threat Is the interception of classified or
sensitive data by foreign nations, terrorist groups and criminal
elements. If the problem is interception then there is not so
much concern at TUX.
Each of the above groups have different Interests.. The
Interception problem has been with us for many years and it is
manageable. Procedures exist for government contractors to be
reimbursed for their efforts to secure information. The
terrorist problem is on the increase. Terrorists are becoming
?
more sophisticated. There is some unanimity among knowledgeable
people In the government that terrorists by design do not perform
large coordinated efforts. Rather they perform spectacular
operations with relatively few people to bring about political
change by public opinion and feelings of insecurity. There are
however enough of the more notorious terrorist groups in the
United States TO perform coordinated operations if they uent
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to. Power systems and communication system have been targets in
Central America - primarily Transmission towers, power stations
and antennas.
It is no clear who is interest in TT&C. The following
questions address the TT&C problem and tend to help carriers to
understand the problem to be solved.
THREAT
(1) Who is the "enemy"?
(2) Why does he want to access the satellites?
(3) What does he want to do with the satellite?
(4) Does he want temporary disruption, permanent
disruption, destruction, or to steal it?
(5) What technique will he use?
(6) What are his assets to acquire access to the satellite?
(7) How many satellites can he access at once and how
frequently?
(8) Is there a factual background that indicates that he
will, in fact, make an attempt to access a satellite,
or is there just a suspicion that he may possibly act
against a satellite?
(9) Why Is accessing the satellite preferable to jamming it
or destroying it?
TECHNOLOGY
(1) Are there more than four options for the protection of
the TT&C of the satellites?
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(a) 0 E S - Available now.
(b) NEW N S A algorythm - Available 6 18 months.
(c) Jamming the uplink - Available now.
(d) Inhibit system - Available 6 - 12 months.
(2) How long will the DE $ equipment be acceptable as a
means of protection to N S A? 1 - 3 years, 3 - 6
years, over 6 years?
(3) How long will the new N S A algorythm be acceptable to
N S A as a means of protection? 1 - 5 years, 1 - 10
years, over 10 years?
(4) Jamming the uplink appears to be a good means of
prohibiting access to the satellite. Why is this more
cost effective technique not acceptable against such an
Ill defined threat?
(5) Is the "inhibit" system capability an acceptable amount
of protection when coupled with a jamming capability?
(6) Most carriers have in orbit spare satellites in event
of the catastrophic loss of an operational satellite.
Is this considered as protection?
(7) What is the government intent - why?
There will be further demands on carriers to protect other
portions of their systems. We need to look at the most cost
effective means to provide realistic pr. tion.
John Boning
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RCA American Communications, Inc I 400 College Road East Princeton, NJ 08540 I Tel (b09) /344000
February 8, 1985
Mt. Herbert Neuman
Executive Secretary, NIACC
Federal Communications Commission
Room BB #324
Washington, D.C. 20554
RCA
APPENDIX F
Dear Mt. Neuman,
As per your request, enclosed is the summary of my remarks at the
National Industrial Advisory Committee Common Carrier Communications
Sub-committee meeting on the protection of telemetry tracking and
control (TM) for commercial satellites of 29 January 85.
Please feel free to call on me if I can be of any further assistance.
Best regards,
in, Mgr.
Mission Operations
JL: eb
cc: J. Boning
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PRU1 U., 1 lUN kik 1tLtML1zu, i KALAIINV, ?i1/44
(secure commanding)
Commercial Communications Satellites are said to be vulnerable
to unfriendly intrusion via the command system with the
intruders ultimate aim of disruption of communications service.
and for incapacitating the satellite for extensive periods or
permanently. The preceding attacks are said to be particularly
inopportune were they to occur during periods of urgent need.
such as a world crisis or national emergency. It is during
such periods that the Government would like to be able to count
on the availability of commercial communications satellites to
continue Government business carried theron to a large extent
and/or to supplement other Government owned communication
capacity. Commercial communications satellites comprise an
available resource of major proportions (approximately 20
satellites - 1985 and more than double that number currently
authorized and expected to be launched by 1986).
It should be noted that the given objective of a "long term" or
permanent denial of communications service ascribed to the
unfriendly intruder can be attained via means other than
spoofing the satellite command system, some of which might be
attainable more effectively by certain types of unfriendly
agents. For example, destruction of Earth Sensors via lasers.
destruction of the communications or command receivers via high
power klystrons (Giga Watts-pulsed) currently available or
under development, placing noise generators near TT&C sites
within side lobes of ground TT&C antennas effectively
precluding telemetry reception, jamming either the
communications or command receivers with high power carrier or
physically destroying TT&C sites. Thus command system
intrusion is an avenue of attack, singled out, perhaps out of
context with the total range of interrelated possibilities.
Within the above context, the suggested countermeasure of
commercial communications satellites command link encryptions
without assessment and in isolation of other attack
possibilities is perhaps premature. Limiting this discussion
to command link intrusion, however, other counter measures
intended to deny unfriendly access can be named, with
potentially less costly consequences:
1. High Power Command Carrier - permanently on and beamed to
the satellite. Given the typical FM satellite command
receiver with limiting, unfriendly intrusion would be
possible only by another carrier whose power levels were
2-4 dB higher. With existing dedicated, per satellite
large apperture (9-14 meter) antennas at TT&C sites, this
approach would effectively limit all but resource rich
potential intruders.
2. Satellite Command Antenna Beam Shaping - The typical "omni"
antennas providing broad coverage during transfer orbit or
during spinning of the satellite is not considered here.
Generally commanding via omni antennas requires
significantly (10dB) more power than via the communications
antenna. Additionally this antenna can be switched "off"
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when on-orbit, and automatically reconnected should the
satellite lose earth lock and begin to spin out of the
communications antennas "footprint".
The potential intrusion threat is greater when command
receivers are accessed via the high gain communications
antenna with its expansive conus coverage and beyond
footprint area.In contrast, on-orbit commanding needs can
generally be satisfied by very limited "spot beams" or
significantly narrowed footprint drastically decreasing the
gain from offshore or transborder regions. This would
require the intruder to use substantially greater resources
to provide very large (30 meter +) antennas, to gain
commanding access outside of the "footprint" area.
3. Raise The Command Receiver Threshold - commandable while
on-station, necessitating higher power by the intruder.
4. Provide Intrusion Detection - via Telemetry.. This
capability currently exists in a number of sitellites.
This implies an override capability from the detecting TT&C
sites.
The preceding are but a few ideas that come to mind. They can
be used singly or in combination. Each is effective to a
greater or lesser degree on the type of intruder threat
postulated:i.e. it is scenario dependent.
The same can be said of command link encryption. The scenario
of a hostile command jammer threat, for example, would, if
allowed to persist long enough (hours to days). result in loss
of communications or loss of the satellite even with encryption.
In some cases jamming might, as is likely to be the case-by
design, force the command system to revert to a "clear text"
mode, allowing intrusion freely.
The common thread throughout the preceding discussion is
commanding power. An intruder without the ability to keep out
TT&C attempts to overcome or correct whatever upset might have
been caused by him, will prove less effective. As discussed
earlier, encryption can be defeated via jamming of the command
link or the telemetry link. Thus the ultimate counter to a
potential intruder is the ability to uplink more power than the
intruder, short of receiver destruction. A continuous high
power carrier will effectively keep all lower power intruders
out and retain control of the satellite. Spread Spectrum may be
the optimum approach to high power systems.
The preceding represent some ideas on the subject of satellite
command link protection from hostile intruders whose objective
is said to be the long periods (days to weeks) or permanently
denial of a satellites communications capacity. It enumerates
without discussion some other possible attack scenarios aimed
at the same end. Clearly, a comprehensive "system" assessment
as to the "Threat" and its countermeasures needs to be made
before a determination as to the nature and scope of command
protection is undertaken.
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