Abstract
The Department of Homeland Security holds
the statutory mission to protect the nations
critical infrastructure which is composed of
nationally significant systems and assets.
The loss of this infrastructure would result
in debilitating consequences to the safety
and security of the United States. Based on
a meta-analysis of government policies, the
current critical infrastructure protection
efforts may be misdirected even though it is
the cornerstone mission of the department to
prevent terrorism and enhance security. Even
when a facility is destroyed, the consequences
may be more complex than a blanket mission of
protecting all facilities against all threats and
hazards can address. These findings can justify
reducing the scope of the current infrastructure
protection mission by assuming a greater
level of resilience within complex systems
and adopting a risk-based methodology for
evaluating only the infrastructure that would
cause debilitating impacts on the safety and
security of the nation.
Introduction
Terrorist attacks can shake the foundations
of our biggest buildings, but they cannot
touch the foundation of America. These acts
shattered steel, but they cannot dent the steel
of American resolve.
President George W. Bush, September 11,
20011
The literal foundations of the United States
are the critical infrastructure (CI) systems that
provide essential-to-life services on which the
American people are dependent. DHS asserts
that these CI systems are so vital to the United
States that their incapacitation or destruction
A Case Study Analysis
David Riedman
would have a debilitating effect on security,
national economic security, national public
health or safety, or any combination thereof.2
Even after the Twin Towers fell, America
remained capable of functioning, and President
Bush said that night, the functions of our
government continue without interruption
our financial institutions remain strong, and the
American economy will be open for business, as
well.3
While the attack had caused fear and
disruption, it had not crippled an enormously
complex and resilient national system of
infrastructure facilities. If terrorists cannot
damage the functionality of America (even
on the local level) by toppling 100-story
commercial high-rise buildings, what kinds of
facilities would have a debilitating impact on
the entire nation if they were destroyed?
This article presents portions of the Center
for Homeland Defense and Security (CHDS)
Masters Thesis How Critical is Critical
Infrastructure? which explores the idea that
not all infrastructure designated as critical
meets the definition of criticality; sometimes
when supposedly critical infrastructure,
especially commercial facilities, are damaged
or destroyed, it turns out the facility was not
critical after all. The overall systems of essentialto-life infrastructure across the country are
more resilient than the current methodologies
presuppose.
This research is a meta-analysis of
government policies on infrastructure
protection intended to address the question
of how these facilities became designated as
critical and whether the scope of the current
infrastructure protection effort is inhibiting the
departments ability to accomplish the mission.
This research is limited to the risk evaluation,
vulnerability assessment, and protection of
physical infrastructure facilities.
Questioning the Criticality of Critical Infrastructure:
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Riedman, Questioning the Criticality of Critical Infrastructure 2
Definition of Critical
Infrastructure
Federal government reports, plans, policies, and
directives from the 1980s to today emphasize
that CI is comprised of the interconnected
systems that can cause debilitating impacts
to the safety and security of the nation if
they are destroyed by natural disasters or
terrorism. Key documents in defining this
protection mission have included President
Clintons Executive Order 13010, the USA
PATRIOT Act, Presidential Policy Directive
63, multiple iterations of the National Critical
Infrastructure Protection Plan (NIPP), and
the 2014 Quadrennial Homeland Security
Review. As the concepts within the policies
have developed over time, the definition of
CI has remained focused on those nationally
significant systems and assets, the loss of which
Table 1. Analysis of Definitions of Critical Infrastructure
Year Document Nationally Significant
Provide
Vital
Service
Interdependent System
Debilitating Impact
Safety of
Public
2014 Quadrennial
Homeland Security Review
X X X X X
2013 NIPP X X X X
2013 PPD-21: CI X X X X X
2013 Executive Order
13636
X X X X X
2011 NCIPP Level 1/
Level 2 Program
X X X X X
2009 NIPP X X X X X
2008 NIPP SRTLTT
Guide
X X X X X
2007 National Security
Strategy1 X X X X X
2005 Interim NIPP X X X X X
2003 HSPD 7 X X X X X
2001 USA PATRIOT
Act
X X X X X
1998 PDD/NSC-63 X X X X X
1996 Executive Order
13010
X X X X
1988 Congressional
Budget Office
Report
X X
would result in debilitating consequences to
the safety and security of the United States.
As demonstrated by Table 1, thirteen
overarching federal government policies
released over the past 19 years consistently
describe critical infrastructure as being
nationally significant, providing vital services,
being part of an interconnected system, causing
debilitating impacts if destroyed, and providing
a service necessary to the health and safety of
the general public.
DHS currently provides a wide-ranging
list of facilities within 16 different sectors that
are considered to be critical.4
Based on this
analysis, infrastructure that lacks national
significance, criticality, and interconnectedness
to other infrastructure systems does not meet
this definition. This creates a discrepancy
between the federal policies that define critical
infrastructure and how DHS currently addresses
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Riedman, Questioning the Criticality of Critical Infrastructure 3
its statutory infrastructure protection mission
to identify, prioritize, and protect the nations
most vital infrastructure.5
Federal government documents over
the past 35 years have a consensus in their
definition of CI being the systems and assets
that are nationally significant, the loss of which
would result in debilitating consequences to the
safety and security of the United States. This
represents a significant incongruence between
the federal policies which define CI and the way
DHS currently views infrastructure facilities.
While DHS takes an all-inclusive approach to
include as many facilities as possible under the
designation as critical, CI has consistently
been defined as only the systems that are
nationally significant. This problem is apparent
when looking at the commercial facilities sector
due to the measures of criticality that relate to
physical attributes of the facilities, but which do
not relate to nationally significant essential-tolife services or maintaining economic security.
To challenge the current CI protection
policies relating to commercial facilities
further, case studies of the World Trade
Center (WTC) and the Las Vegas Strip raise
questions regarding general assertions of the
negative economic impact occurring after the
destruction of a critical commercial facility. A
case study of the 2014 toxic chemical spill into
the primary water source serving Charleston,
West Virginia also provides an example that
is contrary to the argument that the loss of a
facility serving as sole provider of an essentialto-life service results in debilitating impacts
across all infrastructure sectors within a local
area.
Case Studies of Seemingly
Critical Facilities
The facilities that DHS designates as CI should
cause debilitating impacts to the nation if
destroyed, but what if the loss of these facilities
did not even have a debilitating impact on
a local level? The destruction of the original
WTC, the destruction of 14 Las Vegas Strip
casinos, and the chemical contamination of the
sole water source in Charleston, West Virginia
did not result in debilitating local impacts.
Surprisingly, the New York and Las Vegas cases
actually lead to positive economic impacts at
the local level.
It should be noted that the loss of human
lives can occur with the destruction of critical
facilities, but the IP mission is not always
focused on reducing human losses. In 2013,
32,719 traffic collision fatalities occurred on
roadways6
that fall under the CI transportation
systems sector, but it is the mission of
DHS to protect the physical transportation
infrastructure from terrorist attacks rather
than investing resources to prevent thousands
of annual deaths from occurring during vehicle
accidents on the highways.7
It is within the
scope of the DHS mission to assess how a bridge
could be attacked with explosives by terrorists,
but not to assess if installing higher guardrails
could prevent a car from accidently driving off
the bridge.
The commercial facilities sector is an
example of facilities currently deemed to be
CI, but the analysis within the following case
studies shows that the buildings were not
essential to the nation, not single points of
failure, and not providing functions upon which
other infrastructure systems were dependent.
These commercial facilities are not critical due
to redundant and resilient functions within this
sector. As the analysis of the Lower Manhattan
office market demonstrates, resiliency occurs
within the subsectors, and as a result, the
impacts from facility losses were not nationally,
regionally, or even locally significant. In New
York, when office buildings were destroyed by
the 9/11 attacks, others were readily available
to absorb the demand for office space within
the local market.
Refining the methodology for how facilities
are categorized as critical, or not critical, can
reduce the total number of CI facilities and the
overall complexity of evaluating infrastructure.
Removing the critical designation from
facilities that do not cause national devastation
or cascading effects to other infrastructure
when destroyed can be beneficial by allowing
DHS to refocus resources on fulfilling the
departments statutory mission of protecting
essential infrastructure systems.
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Riedman, Questioning the Criticality of Critical Infrastructure 4
Case Study 1:
How the Loss of World
Trade Center was Critical
to Redeveloping Lower
Manhattan
The large brokerage houses that once lined
Wall Street and its cavernous side streets have
spread far and wide in Manhattan, a reflection
of how the area south of Chambers Street is
no longer the dominant financial services
center it once was. With aging buildings that
cannot accommodate huge computers, and
a declining need for financial companies
to be near each other, The Street and its
neighborhood are mere reminders of what
they once were.
New York Times, 19948
A steady exodus of banks, brokerage houses
and insurance companies in recent years
has left the capital of capitalism struggling
at the very moment the economic system it
epitomizes is sweeping the planet.
Boston Globe, 19969
I think it is inevitable that Downtown [Lower
Manhattan] will reinvent itself once again.
The process is already underway, and I am
very optimistic about its future.
David Rockefeller, 200210
Its 1 World Trade Centers stunning
combination of ultra-modern design and
super-sustainable efficiency that makes it a
truly towering achievement.
WTC.com Marketing Material, 2015
Before September 11, 2001, twin landmark
towers stood over the New York City skyline
(Figure 1), but many of todays amenities that
make Lower Manhattan one of the most valuable
real estate markets in the world did not. No
Fulton Street Transit Center existed to organize
a jumble of train lines and buses. A walkable
park hosting more than 500 free concerts and
waterfront condominiums stretching along the
Hudson River also did not exist. The Downtown
Connection bus line did not bring 800,000
annual riders to the area. Thirty billion dollars
in combined public and private investment
was not available to transform the aging WTC
into a gleaming Class-A Leadership in Energy
and Environmental Design (LEED) Platinum11
property. Visitors now stay in nearly 8,000
hotel rooms, which is triple the number that
existed before 2001.12
The 9/11 attacks were the largest loss of
life in American history from terrorism and a
major national tragedy. But out of the rubble,
the economic landscape of Lower Manhattan
transformed in a manner that would never have
been possible without the total loss of the WTC.
Figure 1. New York City Skyline in 1995 and
2014.13
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Commercial Real Estate in
Manhattan
Manhattan is now one of the largest commercial
office markets in the world. According to 2014
tax records, 1,941 commercial office buildings
are valued at $95.6 billion.14 In 2000, it was
assessed at $42.9 billion15 ($58.9 billion
adjusted to 2014 inflation16), which shows the
property values have almost doubled in the last
13 years since the 9/11 attacks, as illustrated in
Figure 2.
While the destruction of the WTC caused a
major impact to the area, things were not in
great shape prior to the attack. The year 1995
was the lowest point in a troubled decade for
Lower Manhattan. Nineteen of the 20 largest
stock brokerage houses had closed, 18 of the
20 largest advertising firms had left, and only
seven of the original 35 Broadway theaters
remained open. Thomas Leuck described the
situation thusly,
[t]he flight of major brokerage houses and
investment banks has left the neighborhood
burdened by old office buildings, with nearly
a quarter of their space vacant, and with
their prospects of luring tenants undermined
by small floors, poor ventilation and wiring,
and outdated architecture. Now, while they
still need larger and more modern buildings
than can be found on the blocks around Wall
Street, the priority of many of the securities
companies is to find the best deals they can
strike on corporate real estate, with few
reservations about moving off the beaten path
in Manhattan.17
Tax incentives and large amounts of
vacant office space allowed tenants outside
the financial industry to move into Lower
Manhattan. In 1996, major tenant additions
included American Airlines, Pfizer Inc,
and Gruner & Jahr USA Publishing. Mayor
Giulianis Wall Street revitalization plan
also called for converting office spaces into
residential properties. Vacancy rates still
remained around 70% and the square footage
rate for the American Airlines 15-year lease was
only $33 ($45.3 adjusted to 2014 inflation) per
square/foot (the new WTC is currently leasing
for $72/ft).19
Figure 2. Assessed Property Values in Lower Manhattan between New York City Fiscal Year 19912000.18
At the center of the changing office market,
which was transitioning from stockbrokers
and advertising to a variety of international
businesses, was the WTC towers. The Twin
Towers were designed and built during the
heyday of big Wall Street brokerage houses and
included 7.6 million square feet of space, which
were not designed for computers and modern
office amenities. In 1995, the WTC had a 25.1%
vacancy rate, which meant that nearly 2 million
square feet of space was vacant (an entire
40-story high-rise building of empty space).20
The enormous amount of vacant space at the
WTC negatively impacted real estate and rental
prices throughout the entire area.
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Loss of the World Trade Center
In the aftermath of 9/11, without the WTC
(original or new), the office space market in
Manhattan was well positioned for growth.
The immediate aftermath of the 9/11 attack
caused fear across the American public but
did not deter citizens and businesses from
quickly returning to Ground Zero. In 2004, the
City of New York Independent Budget Office
forecasted that office employment would regain
the peak it had reached in 2000 by 2010. It
appeared that currently vacant space, as well
as space expected to come on-line during the
20052010 period (i.e., Time Warner Center, 1
Bryant Park, the New York Times building, and
the Bloomberg building) would be sufficient
capacity to accommodate the new workers
even while the trade center buildings remained
under construction.21
According to the Independent Budget Office,
the destruction of the World Trade Center and
damage to surrounding buildings removed
roughly 30 percent of the downtown Class-A
office inventory. Contrary to expectations, this
loss did not result in a spike in rents caused
by the precipitous decline in supply. Instead,
the spreading impact of employment losses
due to the local recession that had started in
the spring of 2001 and accelerated after the
attack, combined with the existence of leased
but unoccupied shadow space in midtown
and downtown, enabled the real estate market
to absorb most of the displaced tenants with
little effect on rents. Instead, downtown
vacancies grew and rents fell during 2002
before stabilizing somewhat during 2003 and
2004.22
As demonstrated by Figure 3, commercial
office leasing peaked in 2002 following the loss
of the WTC and the need to secure new office
spaces. Above average leasing continued in
2003 and 2004. As the new WTC and other
redeveloped Lower Manhattan properties have
opened, office-leasing activity peaked in 2013
and 2014.
Creating New Markets
The criticality of an individual facility, even an
enormous commercial facility like the original
WTC, is nearly impossible to evaluate because
even though it seems to be counterintuitive,
the destruction of the old WTC allowed for the
creation of a more valuable facility.
Figure 3. Lower Manhattan Commercial Leasing Activity 20012014.23
The original seven building WTC site
contained 11.2 million square feet of office
space, which accounted for 4% of the total
office inventory in all of Manhattan.24 If the
original WTC were 100% occupied with the
hotel maintaining peak average occupancy,
the combined site properties would generate
a maximum of approximately $545 million in
annual revenue, as demonstrated in Table 2.
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Riedman, Questioning the Criticality of Critical Infrastructure 7
Table 2. Original World Trade Center Maximum Leasing Revenue Estimate
Property Square Footage2 Price per SquareFoot
Total (Adjusted
to 2014 Inflation)
1 World Trade Center 3.8 million $47.00 $178,600,000
($245,534,550)
2 World Trade Center 3.8 million $47.00 $178,600,000
($245,534,550)
3 World Trade Center
(Marriott Hotel)
825 hotel rooms 86.7% occupancy X
$280/night X 365
$73,101,105
($100,497,463)
4 World Trade Center
(9-Story Low-rise)
200,000 (estimated) $47.00 $9,400,000
($12,922,871)
5 World Trade Center
(9-Story Low-rise)
200,000 (estimated) $47.00 $9,400,000
($12,922,871)
6 World Trade Center
(8-Story Low-rise)
180,000 (estimated) $47.00 $8,460,000
($11,630,583)
7 World Trade Center
(retail/47 stories)
1.86 million $47.00 $87,420,000
($120,182,701)
Total: 14 million $544,981,105
($749,225,591)
To attract tenants from multi-national
corporations and compete with surrounding
properties, premium commercial offices are
designated as Class A. Office space rental
prices are grouped in three classes by the
Building Owners and Managers Association
International (BOMA). The classes include:
Class AMost prestigious buildings
competing for premier office users with
rents above average for the area. Buildings
have high quality standard finishes, state of
the art systems, exceptional accessibility,
and a definite market presence.
Class BBuildings competing for a wide
range of users with rents in the average
range for the area. Building finishes are
fair to good for the area and systems are
adequate, but the building does not compete
with Class A at the same price.
Class CBuildings competing for tenants
requiring functional space at rents below
the average for the area.25
By todays standards, the original WTC,
which was built in the 1970s, would likely not
meet the criteria for a Class A building, and
subsequently, would not demand the highest
rates and draw the premier tenants paying top
dollar. The new WTC is designated Class A
and if the buildings are 100% leased, the total
leasing revenue will exceed $1 billion annually
(Table 3).
Table 3. New World Trade Center Maximum Leasing Revenue Estimate
Property Square Footage Price per SquareFoot (annual)
Total
One World Trade Center 3 million (Class A office) $72.44 $217,320,000
2 World Trade Center 2.8 million (Class A office) $72.44 $202,832,000
3 World Trade Center 2.5 million (Class A office) $72.44 $181,100,000
4 World Trade Center 2.3 million (Class A office) $72.44 $166,612,000
7 World Trade Center 1.7 million (Class A office) $72.44 $123,148,000
WTC Transportation Hub 350,000 (retail) $319.00 $111,650,000
12.65 million Total: $1,002,665,000
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Riedman, Questioning the Criticality of Critical Infrastructure 8
Figure 4. Measuring the Effects of the September 11, 2001 Attack on New York City.27
Figure 5. Economic Impact of Redeveloping the World Trade Center Site.29
While the loss totals appear to be staggering,
they are dwarfed by the positive economic
impacts of the redevelopment, which were
estimated to be $15.7 billion annually (direct,
indirect, and induced) in a study produced
for the Lower Manhattan Development
Corporation, as shown in Figure 5.28
The new WTC buildings have the potential to
generate $250 million more in annual revenue
than the old buildings. This total would likely
be much higher because the old Twin Towers
would struggle to compete with surrounding
premium office spaces or the excess office
space across the entire Lower Manhattan office
market would collectively drive down property
values. Instead, the new WTC buildings are the
cornerstone of the revitalized Lower Manhattan
office market.
Cost of 9/11 Attack versus Economic
Impacts of Redevelopment
A 2002 study by the Federal Reserve Bank
of New York Economic and Policy Review
estimated the total losses from the 9/11 attacks
including earning losses, property damage, and
cleanup to be between $33 and $36 billion.26
Of those losses, the physical losses shown in
Figure 4 total $21.6 billion.
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Riedman, Questioning the Criticality of Critical Infrastructure 9
WTC Case Study Conclusion
The loss of life at the original WTC was a tragic
event, but with it, the sudden disappearance
of the original WTC buildings caused a
significant decrease in total square-footage of
available office space, which served to stabilize
an oversaturated and declining commercial
real estate market in Lower Manhattan. Fear
of future attacks did not deter people and
businesses from returning to Lower Manhattan
either. Through public and private investment,
the new WTC has been constructed to be more
efficient in a design that meets the office market
demands of premium clientele in Manhattan.
The smaller but more luxurious office footprint
draws nearly double the price per square-foot
and provides more retail, transit, cultural, and
public spaces for the general consumer.
The $21.6 billion estimate of the capital
losses30 ($16.4 in physical buildings) associated
with the 9/11 attack only represent direct losses
impacting the WTC itself. CI is defined by the
interconnectivity of the systems within each
sector and across multiple sectors. Manhattan
has an estimated $804.4 billion office market
with 32.8 million square-feet of office space.
Compared to the overall office market, the loss of
the WTC represented 2% of the total commercial
office building value while also being 29% of
total office space (in an oversaturated market).31
In addition to stabilizing the office leasing
market, redevelopment has transformed the
mid-1990s Lower Manhattan market, which did
not offer premier real estate, luxury shopping,
world class hotels, destination dining, and
tourism, into an area that produces cumulative
consumer spending of $5.2 billion annually
according to the 2014 Lower Manhattan Real
Estate Market Overview produced by the
Alliance for Downtown New York.32
The 2006 Homeland Security Advisory
CouncilReport on Critical Infrastructure
Task Force reported that the impacts of
terrorism and 9/11 extended well beyond
the direct ground zero effects and were
exacerbated by citizens choices based on their
altered perception of risk. Ultimately, the
ability of CI to recover fully from a catastrophe
depends on the actions of the consumers.33 The
exact ground zero location of the 9/11 attack
has become a tourism destination of itself. The
110,000-square-foot National September 11
Memorial Museum was initially expected to
draw 2.5 million visitors per year, but exceeded
500,000 visitors during the first two months of
operation in May and June 2014.34 The number
of hotel rooms in Lower Manhattan near the
location of the attacks has tripled since 2001,
which demonstrates significant interest as a
destination for tourists (Figure 6).
Figure 6. Number of Hotel Rooms in Lower Manhattan.35
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The loss of the original WTC is a case that
is opposite to the principles of a facility being
critical infrastructure. Rather than causing
debilitating and cascading negative impacts
to the nation or surrounding region, the loss
of the buildings was a net-positive to the
components of the commercial facilities sector
in Lower Manhattan. It is unlikely that a viable
plan would have been available to demolish
and rebuild the WTC without an unplanned
event destroying it. Without the 9/11 attack,
the continued existence of the original Twin
Towers would have resulted in sustained oversaturation of the Manhattan office market with
an excess amount of outdated and undesirable
Class B office space. Over the past decade, the
office market pressure has continued to grow for
LEED Certified and Green Office space, which
would have continued to decrease the price per
square-foot at the WTC as surrounding buildings
drew away Class A customers.36 The enormous
amount of office space within the original Twin
Towers would have likely continued to depress
the surrounding market and economic growth,
and deter capital investment into the area.
The original WTC buildings and commercial
facilities in general should not be considered
critical infrastructure because commercial
markets are too complex with numerous
contributing variables for DHS or a group of
industry representatives to make assumptions
that individual facilities are supremely
important. It is very unlikely that anyone would
have said the largest building in New York
City was not critical, but the destruction of it
paved the way for massive redevelopment and
economic growth, as seen in Figure 7.
Figure 7. 1 World Trade Center Website.37
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While it was unforeseeable at the time, the
Lower Manhattan area that was most heavily
impacted by the September 11, 2001 attacks is
more valuable today and better positioned for
the future than it was prior to 2001. If terrorists
cannot cripple this nation by toppling 100-story
commercial high-rise buildings, what kinds of
facilities would have a debilitating impact on
the entire nation if they were destroyed? Instead
of being designated critical, the majority of
infrastructure facilities are insignificant to the
functions of the overall system because the loss
of these facilities does not cause widespread
disruptions to the nation, region, or even the
local area. The worst circumstances may spur
the greatest opportunity for positive change,
which could shift homeland security strategies
to focus primarily on effective recovery rather
than protecting existing systems.
Case Study 2:
Las Vegas Casinos and
Critical Infrastructure
The National Strategy for the Physical
Protection of Critical Infrastructure and Key
Assets assigned DHS with the responsibility to
develop a uniform methodology for identifying
facilities, systems, and functions with nationallevel criticality to help establish protection
priorities; build a comprehensive database to
catalog these facilities, systems, and functions;
and maintain a comprehensive, up-to-date
assessment of vulnerabilities and preparedness
across critical sectors.38
Below the national level, DHSs Regional
Resiliency Assessment Program evaluates
clusters of CI and key resources within a
geographic area. In a regional geographic area,
jurisdictions have different interpretations of
the types of facilities critical to their jurisdiction,
to the larger region and the nation. According
to a DHS grant funded study, Clark County:
Critical Infrastructure and Key Assets,
produced by Urban Environmental Research,
[t]he protection of the nations infrastructure
assets (or critical infrastructure) from
disruption and destruction is a primary
function and concern of all levels of
government. Clark County, internationally
known for the Las Vegas Strip and lavish
casino entertainment (Figure 8), is unique in
that the structure of the local economy is built
primarily on gaming. In the evaluation of
critical assets in Las Vegas, Nevada, the most
important assets are clearly the casinos and
glitter of the Strip.39
Presidential Policy Directive/PPD-21
defined CI as the systems and assets, physical
or virtual, so vital to the United States that the
incapacity or destruction of such systems and
assets would have a debilitating impact on
security, national economic security, national
public health and safety, or any combination
of those matters.40 The Clark County: Critical
Infrastructure and Key Asset report describes
the international and national significance
of Las Vegas and The Strips casinos as the
most critical assets, but are these commercial
facilities even critical at the local level?
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What Gaming Facilities Subsector
Members Expect from DHS
The National Infrastructure Protection
Plan: Commercial Facilities SectorAnnex
2: Gaming Facilities Subsector describes
the facilities in the sector as soft targets
vulnerable to the publics fear and perceptions
of security. To protect casinos from potential
terrorist attacks, the costs of making physical
changes are significant and a need exists for
tax incentives to reduce the economic burden
on owners for making improvements. The
goal of the subsector is to implement security
measures that are efficient, cost-effective, and
as unobtrusive as possible.42 Across the gaming
subsector, facilities have expressed concerns
over sharing assessment information with the
Federal Government for any initiative that
makes formal decisions on the prioritization of
assets (i.e. concluding that one asset is more at
risk than another).43
The gaming subsector cites $5.6 billion in
direct gaming tax revenue as the justification
for federal resources and protection as CI
facilities, but the requests of the subsector
council include tax incentives, which would
reduce this revenue. To distribute resources
across 445 facilities effectively, DHS must make
a determination of risk, priority, and criticality,
but the gaming subsector also does not support
any effort to document one facility as more
important than others.44
Las Vegas Casinos
In planning for protection of a CI facility such as
a Las Vegas casino, protective measures would
address the use of explosives by terrorists
to damage or destroy the building. Since the
economic depression in 2006, explosives have
destroyed many of The Strips critical casinos,
but these explosives were planned detonations
to implode vacant buildings intentionally.
Since 2006, the Castaway, Boardwalk, Bourbon
Street, Stardust, New Frontier, and Klondike
casinos have all been imploded. During the same
time period, the Lady Luck, Sahara, Western,
OSheas, Gold Spike, and Riviera casinos have
Figure 8: Image of the Fabled Riviera Casino That Closed on May 4, 2015.41
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Riedman, Questioning the Criticality of Critical Infrastructure 13
Figure 9. Population of Las Vegas, NV by Year.47
Figure 10. Nevada Real Per Capita Income per Year.48
all closed.45 The implosion of six casinos and the
closure of six others over the last decade means
that 12 of Las Vegas 87 casinos (currently 75
are open), or 14%, of these CI facilities have
been lost.46 The loss of a critical facility should
result in debilitating impacts to the nation, so
how has the loss of 12 critical facilities impacted
the local area in Las Vegas?
From 2005 to 2013, the population of Las
Vegas has increased from 544,608 to 603,448
(Figure 9). Real per capita income increased
slightly from 20052007 before dipping to 15%
lower than pre-casino closures at $25,918 in
2013 (Figure 10). Residential rental rates have
remained fairly constant over the same time
period (Figure 11).
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Riedman, Questioning the Criticality of Critical Infrastructure 14
Figure 11. Monthly Rental Rates Las Vegas by Year.49
In Las Vegas, the casinos are considered
to be critical facilities, which would result in
debilitating impacts to the local economy if
they were destroyed, but as 14% of the casinos
were imploded or closed, the population of the
city increased while median rental prices and
incomes remained fairly constant.
The casinos that have closed permanently or
been demolished in Las Vegas had previously
been cornerstones of The Strip. The most recent
facility to close is the Riviera Hotel and Casino,
which was the first high-rise built in the area
in 1955, and which included 2,100 hotel rooms.
The hotel featured A-list celebrity guests,
professional boxing title fights, and performers
including Elvis Presley and Louis Armstrong.50
While 1,200 employees at the Riviera lost
their jobs, more than 950,000 of 1,029,70051
employable people in Las Vegas remain
employed, maintaining an unemployment rate
of 7.2%, which is just over the national average
of 5.4%.52
If the loss of critical infrastructure casinos
in Las Vegas did not result in widespread
detrimental impacts to the city, should
these facilities be considered to be critical
infrastructure to Clark County, Nevada? If the
impacts of the closures were negligible at the
local level, it is unlikely that these casinos have
any regional or national implications to CI.
Resiliency within the Las Vegas
Casino Industry
While the Clark County: Critical Infrastructure
and Key Asset report describes The Strips
casinos as the most critical assets, it is not
the individual physical properties that are
critical, it is the overall gaming industry that is
essential to the city. The individual properties
are not critical, as shown by the 12 casinos
closed between 2006 and 2015 without causing
major disruptions to the tourism industry
(Figure 13), hotel occupancy (Figure 13),
or gaming revenue (Figure 12). When DHS
determines how to spend federal funding for
providing protection to CI, not a single casino
needs protective measures, and it would be
prohibitively expensive to protect every casino
against all threats. In a terrorist attack scenario,
simultaneously destroying all 80 casinos on the
Las Vegas Strip would be the largest terrorist
attack in world history, and is very unlikely
to occur. The gaming industry in Las Vegas is
already protected by the resiliency within
the network of eight casinos along The Strip.
An attack against a single casino, or group of
casinos, would not cause the entire gaming
industry to crumble because the loss of 12 casinos
to closure has not significantly impacted key
indicators (visitors, hotel occupancy, and tax
revenue). An attack across the entire industry
is not realistic. In other words, the protection of
the key asset (gaming industry) already exists
within the current system without additional
assistance from federal funding and resources.
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Riedman, Questioning the Criticality of Critical Infrastructure 15
Figure 12. Annual Tax Revenue of Las Vegas Strip Casinos 20012012 via University of Las Vegas
Center for Gaming Research.53
Figure 13: Las Vegas Visitor Statistics from Visitor and Convention Authority.54
The Clark County: Critical Infrastructure
and Key Asset report also describes that a
terrorist attack would deter visitors from
traveling to Las Vegas, which would be
extremely detrimental to the hotel and gaming
industry. Following the 9/11 attacks in New
York City, annual tourism has increased every
calendar year since 2001. In 2013, 54.3 million
people visited New York City, which is 16
million more than 2000 (36.2 million).55 The
exact site of the terrorist attack has also drawn
19 million visitors to the 9/11 Memorial since it
opened in 2011, which suggests that a terrorist
attack occurring at a facility is not necessarily
a deterrent to future visitors. Furthermore, a
memorial for the attack may become a tourist
destination in itself.
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Riedman, Questioning the Criticality of Critical Infrastructure 16
Individual Gaming Facilities are Not
Critical Infrastructure
At the federal level, the gaming facilities
subsector uses total gross revenue and tax
revenue as the justification for the inclusion of
casinos as CI. The DHS gaming subsector also
does not identify individual facilities as being
more or less critical than other gaming facilities.
Choosing not to delineate importance (based on
revenue, economic impact, tax base, population,
or any other measure) aligns with the concept
of the resiliency that has been demonstrated
across the Las Vegas Strip casinos. No individual
casino in the country has significant impacts on
the gaming industry at the local, regional, or
national level. A network of hundreds of gaming
facilities provides a variety of gambling options
even if specific locations are unavailable due
to business closure, a terrorist attack, or any
other reason. This resiliency within the gaming
subsector buffers disruptions and allows for a
steady generation of revenue without the need
for federal resources to be dedicated to the
protection of specific gaming facilities.
Case Study 3:
Scarcity of Function and
a Single Point of Failure
for The Charleston, West
Virginia Water Supply
Clean water is essential to human survival across
the world. A mix of public and private utilities
provide water services in the United States, and
protection of these critical services falls under
the DHS CI water sector. Loss of water services
causes both an immediate risk to human health
and cascading impacts across other CI sectors
dependent on water services.56 Prioritizing
the protection of water infrastructure on the
nationwide level is described in the 2010
NIPP Water Sector Specific Plan through the
evaluation of higher-consequence and higherpriority utilities. The plan further specifies
that four criteria are used to better identify
these national level high-consequence assets:
(1) population served; (2) amount of chlorine
gas stored on site; (3) economic impact; and (4)
critical customers served.57
In January 2014, a toxic chemical spill of 10,000
gallons of 4-methylcyclohexanemethanol
contaminated the Elk River one and half
miles upstream of the City of Charleston in
West Virginia. This spill resulted in the total
contamination of water services (drinking,
washing, bathing) to 300,000 residents in nine
counties.58
Public water utility service was the primary
source of water for the majority of the residents
in the area:
17.6% of residents reported having
rainwater and 5.6% reported well water
available, which resulted in the majority of
residents requiring bottled water because
tap water was not available.
37% of residents reported using tap water
during the do not use order, which showed
that adequate supplies of bottled water were
not available for all water related activities
including showering/bathing.
78.8% of users during restriction showered/
bathed with contaminated water.59
The chemical spill into the Elk River is an
example of both a scarcity of function and
a single point of failure in an infrastructure
system. Municipal water service was the
primary provider of clean water (an essentialto-life service) for the residents of Charleston
and the surrounding counties. Without the
municipal water service, a scarcity of function
occurred because other sources were unable
to provide adequate supplies of the necessary
service to the population. The upstream
contamination represented a single point of
failure in the water service system because no
alternate source was available from which the
water treatment facility and water system could
draw. The chemical spill into the sole water
supply for the majority of citizens caused the
entire water service infrastructure to fail.
This failure of the water infrastructure
system is an example of a CI system critical
to the local jurisdiction. The lack of water
services in an isolated area was not regionally
or nationally significant to water infrastructure
systems. The lack of water to this isolated area
was also not debilitating to the region or the
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Riedman, Questioning the Criticality of Critical Infrastructure 17
nation. This example is useful for studying
scarcity of function and single points of failure
in a CI system.
Currently, DHS measures the consequences
of loss of water services by evaluating the
public health effects, economic impacts,
psychological impacts, and interdependencies
and dependencies with other infrastructure
sectors.60 It seems more useful to evaluate the
criticality of water systems through the scarcity
of the water infrastructure function and the
existence of a single point of failure in delivery
of the service. At a local and regional level,
resiliency in the delivery of essential services
exists across infrastructure sectors. In the West
Virginia chemical spill, regional and national
systems provided bottled and trucked water in
an effective manner to meet service demands.
The Charleston outage is useful for
evaluating the loss of single sources of essential
functions at the national level. The Hoover
Dam is the sole provider for water service to
1.3 million citizens.61 The Hoover Dam also
holds back a 9.2 trillion gallon62 reservoir
that would require a million gallons of a toxic
chemical to contaminate. In West Virginia, the
mining industry positioned 10,000 gallons of
a dangerous chemical near a waterway but no
million-gallon storage tanks of toxic chemicals
are positioned directly around the Hoover Dam.
It is also not a viable scenario for a terrorist
group, or other enemy, to transport millions
of gallons of a toxic chemical to a nationally
significant water source. It would take 20,000
tractor-trailer trucks carrying 5,000 gallons
of a chemical to amass one million gallons of
a contaminant. Even if the Hoover Dam were
somehow contaminated with a chemical, it
would likely have minimal impact on its ability
to generate four billion kilowatts of power,63 and
the subsequent functions of other infrastructure
sectors dependent on it for water.
Figure 14: Interdependencies with Water Sector Infrastructure from National Infrastructure Protection
Plan.64
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Riedman, Questioning the Criticality of Critical Infrastructure 18
On the national level, do sole providers and
single points of failure exist in CI systems and
services? If they do exist, how large is the scale of
the disruption needed to break the system? For
example, what volume of toxic chemicals would
be needed to contaminate the Hetch Hetchy
Water System that serves 1.7 million citizens65
in San Francisco, CA? Would an accidental or
intentional release of that volume of chemicals
be viable? It is likely not a viable scenario. In
the local case of the Charleston spill, water for
drinking, cooking, and bathing was impacted
but did the contamination have any impact on
other infrastructure systems, such as electrical
power, telecommunications, transportation,
petroleum liquid, or natural gas as shown in
Figure 14 from the National Infrastructure
Protection Plan? A drinking water outage is not
necessarily an outage of all water uses across
every infrastructure function that uses water as
a component.
The January 2016 FEMA Emergency
Declaration66 issued for lead contamination
in the water supply of Flint, Michigan further
emphasizes this concept that the total loss of
a seemingly critical system does not instantly
cripple all infrastructure functions in the
impacted area. There is enough redundancy
within regional and national infrastructure
systems to provide essential water services
through bottled water, federal assistance to
serve as a stop gap to defer the cost of bottled
water, state assistance to repair the municipal
water system, and public-private infrastructure
services to reconnect the Flint area to Detroits
water system as a temporary solution.67
Findings and
Recommendations
The concepts presented within this article
suggest that DHS is failing to fulfill the mission
of protecting the infrastructure that is critical to
the nation by expending resources on misaligned
efforts at thousands of insignificant facilities.
On a local and regional level, redundancy and
resiliency occur across infrastructure systems
that allow affected areas to absorb outages and
unaffected areas to provide alternative services.
As a backstop, national emergency response
capabilities can quickly deliver essential
services during outages, such as the bottled
water supplied to Charleston, WV following
the chemical spill into the water supply. Also,
the enormous complexity within infrastructure
systems makes predicting the impacts of
outages extremely difficult, as demonstrated
by the unanticipated economic gains in Lower
Manhattan following the 9/11 attacks.
While infrastructure systems are
interdependent, redundancy and resiliency
also occur, which allows the larger systems
to continue functioning during disruptions.
Resiliency, or the ability of a facility to continue
functioning, is the opposite of criticality. The
ability of resilient systems to resume or continue
functioning is the opposite of the failures and
breakdowns in systems that DHS uses to frame
the definitions of CI. This concept of resilience
follows the National Infrastructure Protection
Plan, which states that, resilient infrastructure
systems are flexible and agile and should be
able to bounce back after disruption.68 Within
the resilient systems, disruptions that occur
may cause beneficial changes. Policies centered
on guarding a vast array of facilities from all
types of risks potentially have the negative
impact of preventing progress at the expense of
protecting the status quo.
Additional research into CI failures following
the same methodology as the case studies
within this article could determine if negligible
losses, or even positive gains, occurred in a
variety of circumstances. Looking at property
values, tourism, tax revenue, hotel occupancy,
and average rental prices of New Orleans,
LA 10 years prior to and 10 years following
Hurricane Katrina would likely show that the
post-disaster city has made positive economic
gains that position it for a better future.
Greensburg, KS was completely destroyed by
an EF-5 tornado in 2007, but is now known
to be a model green community because all
the buildings have been built to the highest
environmental certification and are wind
powered.69 It is unlikely that Greensburg would
have become a national model of environmental
sustainability without the tornado destroying
all the towns existing infrastructure. In August
2007, the I-35 Bridge over the Mississippi
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Riedman, Questioning the Criticality of Critical Infrastructure 19
River in Minneapolis collapsed and traffic had
to be rerouted until the replacement bridge
opened in September 2008. The bridge would
have been considered a critical component
of the transportation infrastructure, but the
resiliency within the system allowed for a mere
traffic disruption rather than a catastrophic
failure of the entire system occurring.70 While
sports stadiums and arenas are infrastructure
considered critical to the local or regional
economy, these facilities have been frequently
demolished as facilities age or teams are sold,
then relocated. One example is the KeyArena
in Seattle, WA, which housed the NBA Seattle
SuperSonics from 196778, 198594, and
19952008, but which continues to function
in the interim periods without a team and still
provides a venue for various forms of sports
and entertainment today.71 Across the United
States, large shopping malls were the hubs of
commerce, but many are vacant today.72 Many
shopping malls are considered CI by DHS, but
has the disappearance of the physical retail
infrastructure resulted in economic losses to
the surrounding areas?
Also, theoretical scenarios involving the
destruction of infrastructure facilities or
systems should be explored based on the
arguments presented within this article. If
infrastructure systems have high levels of
resilience and following disasters, areas are
redeveloped in a more efficient and valuable
manner, what would happen following a major
cyber-attack that crippled the entire national
power grid? While DHS and the Department
of Energy work on strategies to harden the
existing grid,73 would a catastrophic failure
result in the creation of a decentralized
and sustainable energy infrastructure? The
seemingly worst-case scenario of losing the
existing power grid could eventually result in an
improved energy delivery system, which would
position the country for a stronger future. The
worst circumstances may spur the greatest
opportunity for positive change, which could
shift homeland security strategies to focus
primarily on effective recovery rather than on
protecting existing systems.
Based on these findings, DHS should ensure
that everything designated as critical meets
the definition of criticality, the methodologies
used for evaluating infrastructure align to
the mission of protecting the nation from
terrorism, and protection efforts account for
the existing resiliency within the systems that
provide essential-to-life infrastructure across
the country. Many infrastructure facilities are
inconsequential if attacked, and if the loss of a
facility does not cause widespread disruptions,
it is not CI. DHS should shift from an inclusive
CI policy that allows facilities to self-designate
and self-assess risks to a policy that assumes
facilities are inconsequential to the security
and functions of the nation unless proven
otherwise.
A solution for accomplishing the task
of effectively identifying, prioritizing, and
protecting CI is to refine the criteria for how
facilities are determined to be critical. A lower
number of critical facilities will reduce the
overall scope of the protection mission. Adopting
a risk-based approach for both prioritization of
facilities and evaluation of national impacts
can assist DHS in more effectively designating
facilities as critical.
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Riedman, Questioning the Criticality of Critical Infrastructure 20
About the Author
David Riedman is a Captain in the
Montgomery County, MD Fire and Rescue
Service and an expert in emergency and
disaster preparedness, planning, and response.
Mr. Riedman is a graduate of the Center for
Homeland Defense and Security masters
degree program at the Naval Postgraduate
School and received his undergraduate
degree from Georgetown University. He is
currently an associate at Obsidian, a Cadmus
Company, and supports federal clients with
strategic planning, policy development, and
organizational improvement. He may be
reached at [email protected]
Disclaimer
The views expressed in this essay are those of
the author alone.
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Riedman, Questioning the Criticality of Critical Infrastructure 21
Notes
1. Statement by President George W. Bush in His Address to the Nation, September 11, 2001, https://
www.911memorial.org/sites/all/files/Statement%20by%20President%20Bush%20in%20His%20Address%20to%20
the%20Nation.pdf.
2. What is Critical Infrastructure? August 26, 2015, http://www.dhs.gov/what-critical-infrastructure.
3. Statement by President George W. Bush in His Address to the Nation, September 11, 2001.
4. Critical Infrastructure Sectors, June 12, 2014, http://www.dhs.gov/critical-infrastructure-sectors.
5. The White House, Presidential Policy DirectiveCritical Infrastructure Security and Resilience Presidential
Policy Directive/PPD-21Critical Infrastructure Security and Resilience (Washington, DC: The White House,
2013), http://www.whitehouse..
6. National Highway Transportation Safety Administration, Traffic Safety Facts 2013 Data (Washington, DC: U.S.
Department of Transportation, 2015), http://www-nrd.nhtsa.dot.gov/Pubs/812181.pdf.
7. Transportation Systems Sector, March 25, 2013, http://www.dhs.gov/transportation-systems-sector.
8. Thomas Lueck, Wall Street, No Longer Financial Epicenter, Struggles to Cling to Cachet, The New York Times,
December 26, 1994, http://www.nytimes..html.
9. Peter Gosselin, Wall Street Hits the Wall as Financial World Spins, Leading Firms to Depart the Nations
Economic Capital, The Boston Globe, June 28, 1996, http://www.highbeam.com/doc/1P2-8373110.html.
10. Alliance for Downtown New York, Inc., ADNY Annual Report 2014 (New York: Alliance for Downtown New
York, Inc., 2014), http://www.downtownny.com/sites/default/files/Annual%20Report_2015_Final_Web2.pdf.
11. About: LEED Certification, accessed July 23, 2015, http://www.usgbc.org/leed.
12. ADNY Annual Report 2014, 2014, http://www.downtownny.com/sites/default/files/Annual%20
Report_2015_Final_Web2.pdf.
13. Ibid.
14. Office of Tax Policy, Annual Report: New York City Property Tax FY 2014 (City of New York: Department of
Finance, 2014), http://www1.nyc.gov/assets/finance/downloads/pdf/reports/reports-property-tax/nyc_property_
fy14fmvandav.pdf.
15. Office of Tax Policy, Report on New York City Property Tax FY 2000 (City of New York: Department of Finance,
2000), http://www1.nyc.gov/assets/finance/downloads/pdf/99pdf/rptsum00.pdf.
16. U.S. Inflation Calculator, accessed July 23, 2015, http://www.usinflationcalculator.com.
17. Lueck, Wall Street, No Longer Financial Epicenter, Struggles to Cling to Cachet.
18. Office of Tax Policy, Report on New York City Property Tax FY 2000 (City of New York: Department of Finance,
2000), http://www1.nyc.gov/assets/finance/downloads/pdf/99pdf/rptsum00.pdf.
19. Mervyn Rothstein, The Former Mobil Building, Largely Vacant in the 90s, Gets a New Tenant, American
Airlines, The New York Times, October 29, 1996, http://www.nytimes.com/1996/10/30/business/former-mobilbuilding-largely-vacant-90-s-gets-new-tenant-american-airlines.html.
20. Charles Bagli, Guardian Insurances Plan Adds to Downtown Rebirth, The New York Times, January 8, 1998,
http://www.nytimes..html.
21. City of New York Independent Budget Office, Response to Request to Examine Critical Issues Underlying the
Planned Rebuilding at the World Trade Center Site (City of New York: Independent Budget Office, 2006), http://
www.ibo.nyc.ny.us/iboreports/stringerwtclet.pdf.
Homeland Security Affairs, Volume 12 Essay 3 (May 2016) WWW.HSAJ.ORG
Riedman, Questioning the Criticality of Critical Infrastructure 22
22. City of New York Independent Budget Office, Response to Request to Examine Critical Issues Underlying the
Planned Rebuilding at the World Trade Center Site.
23. Alliance for Downtown New York, Inc., Lower Manhattan Real Estate Market Overview (New York: Alliance for
Downtown, 2014), http://www.downtownny.com/sites/default/files/Q2%202014%20FINAL%20REPORT.pdf.
24. World Trade Center, July 9, 2015, http://www.newworldencyclopedia.org/entry/World_Trade_Center.
25. Building Class Definitions, accessed July 23, 2015 http://www.boma.org/research/Pages/building-classdefinitions.aspx.
26. Jason Bram, James Orr, and Carol Raraport, Measuring the Effects of the September 11 Attack on New York
City, FRBNY Economic Policy Review, November 1, 2002, https://www.newyorkfed.org/medialibrary/media/
research/epr/02v08n2/0211rapapdf.
27. Ibid.
28. Appleseed, Economic Impact of Redeveloping The World Trade Center Site: New York City, New York State,
And the New YorkNew Jersey Area (New York: Appleseed, 2003), http://www.renewnyc.org/content/pdfs/
Appleseed.pdf.
29. Ibid.
30. Ibid.
31. New York City Department of Finance, Tentative Assessment Roll: Fiscal Year 2008 (New York: Department of
Finance, 2007), http://www1.nyc.gov/assets/finance/downloads/pdf/07pdf/assessment_report_08.pdf.
32. Alliance for Downtown New York, Inc., Lower Manhattan Real Estate Market Overview 2014 (New York:
Alliance for Downtown New York, Inc., 2014), http://www.downtownny.com/sites/default/files/Q2%202014%20
FINAL%20REPORT.pdf.
33. Homeland Security Advisory Council, Report of the Critical Infrastructure Task Force (Washington, DC:
Department of Homeland Security, 2006), 6, http://www.dhs.gov/xlibrary/assets/HSAC_CITF_Report_v2.pdf.
34. Alliance for Downtown New York, Inc., Lower Manhattan Real Estate Market Overview 2014 (New York:
Alliance for Downtown New York, Inc., 2014), http://www.downtownny.com/sites/default/files/Q2%202014%20
FINAL%20REPORT.pdf.
35. Ibid.
36. The Business Case for Green Building, accessed July 23, 2015, http://www.usgbc.org/articles/business-casegreen-building.
37. From One World Trade Center, accessed July 23, 2015, http://www.wtc.com/about/buildings/1-world-tradecenter.
38. Moteff, Copeland, and Fischer, Critical Infrastructures: What Makes an Infrastructure Critical? Congressional
Research Service, 2003.
39. Urban Environmental Research, LLC, Clark County: Critical Infrastructure & Key Assets Final (Clark County,
NV: Urban Environmental Research, LLC, 2008, http://www.clarkcountynv.gov/comprehensive-planning/regulatedbusiness/Documents/Studies/CCCriticalInfrastructure0508.pdf.
40. The White House, Presidential Policy DirectiveCritical Infrastructure Security and Resilience Presidential
Policy Directive/PPD-21Critical Infrastructure Security and Resilience.
41. From Brandon Griggs, Fabled Las Vegas Casino Closes after 60 Years, CNN, May 5 2015, http://www.cnn.
com/2015/05/05/travel/riviera-hotel-casino-vegas-closes-feat/.
42. Department of Homeland Security, Commercial Facilities Sector-Specific Plan an Annex to the National
Infrastructure Protection Plan 2010, 81.
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Riedman, Questioning the Criticality of Critical Infrastructure 23
43. Department of Homeland Security, Commercial Facilities Sector-Specific Plan an Annex to the National
Infrastructure Protection Plan 2010, 83.
44. Ibid.
45. Yet Another Las Vegas Casino History Timeline, accessed July 23, 2015 http://www.lvrevealed.com/
deathwatch/las_vegas_timeline.html.
46. Complete List of Las Vegas Casinos, February 1, 2015, http://vegasclick.com/vegas/casinos.
47. From http://www.google.com/publicdata/
explore?ds=kf7tgg1uo9ude_&ctype=l&strail=false&bcs=d&nselm=h&met_y=population&scale_
y=lin&ind_y=false&reim=country&idim=place: 3240000:3260600:3231900&ifdim=country&tstart=
1104642000000&tend=1372737600000&hl=en&ind=false.
48. From Las Vegas-Paradise Nevada Household Income, accessed July 23, 2015, http://www.deptofnumbers.
com/income/nevada/las-vegas/.
49. From Las Vegas-Paradise Nevada Rent and Rental Statistics, accessed July 23, 2015, http://www.
deptofnumbers.com/rent/nevada/las-vegas/.
50. Brandon Griggs, Fabled Las Vegas Casino Closes after 60 Years, CNN, May 5, 2015, http://www.cnn.
com/2015/05/05/travel/riviera-hotel-casino-vegas-closes-feat/.
51. Las Vegas-Paradise, NV Economy at a Glance, July 21, 2015. http://www.bls.gov/eag/eag.nv_lasvegas_msa.
htm.
52. National Employment Monthly Update, July 2, 2015, http://www.ncsl.org/research/labor-and-employment/
national-employment-monthly-update.aspx.
53. From David G. Schwartz, Major Gaming Jurisdiction: Twelve-Year Comparison (Las Vegas: Center for Gaming
Research, University Libraries, University of Nevada Las Vegas, 2013), http://gaming.unlv.edu/reports/12_year_
comp.pdf.
54. From Historical Las Vegas Visitor Statistics, February 1, 2015, http://www.lvcva.com/stats-and-facts/.
55. NYC Statistics, accessed July 23, 2015, http://www.nycgo.com/articles/nyc-statistics-page.
56. Department of Homeland Security, Water Sector-Specific Plan: An Annex to the National Infrastructure
Protection Plan (Washington, DC: Department of Homeland Security, 2010), 13, https://www.dhs.gov/xlibrary/
assets/nipp-ssp-water-2010.pdf.
57. Department of Homeland Security, Water Sector-Specific Plan: An Annex to the National Infrastructure
Protection Plan, 13.
58. West Virginia Bureau for Public Health (WVBPH) and the Agency for Toxic Substances Disease Registry, Elk
River Chemical Spill Health Effects Findings of Emergency Department Record Review April 2014 Collaborative
Investigation by the West Virginia Bureau for Public Health (WVBPH) and the Agency for Toxic Substances Disease
Registry (ATSDR) (West Virginia: Department of Health & Human Resources, 2014), http://www.dhhr.wv.gov/
News/chemical-spill/Documents/ElkRiverMedicalRecordSummary.pdf .
59. Centers for Disease Control and Prevention, Disaster Response and Recovery Needs of Communities Affected by
the Elk River Chemical Spill, West Virginia (Atlanta, GA: Centers for Disease Control and Prevention, 2014), http://
www.dhhr.wv.gov/News/2014/Documents/WVCASPERReport.pdf.
60. Department of Homeland Security, Water Sector-Specific Plan: An Annex to the National Infrastructure
Protection Plan, 25.
61. Hoover DamFrequently Asked Questions, March 12, 2015, http://www.usbr.gov/lc/hooverdam/faqs/
damfaqs.html.
62. Hoover Dam and Powerplant, September 2013, http://www.usbr.gov/lc/region/pao/brochures/hoover.html.
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Riedman, Questioning the Criticality of Critical Infrastructure 24
63. Hoover DamFrequently Asked Questions.
64. Department of Homeland Security, Water Sector-Specific Plan: An Annex to the National Infrastructure
Protection Plan (Washington, DC: Department of Homeland Security, 2010), https://www.dhs.gov/xlibrary/assets/
nipp-ssp-water-2010.pdf.
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