Identifier
Created
Classification
Origin
07RIYADH1987
2007-09-26 09:42:00
SECRET
Embassy Riyadh
Cable title:  

JOINT WORKING GROUP ON CRITICAL INFRASTRUCTURE

Tags:  KCIP EPET ENERG PTER ASEC SA 
pdf how-to read a cable
VZCZCXRO7989
RR RUEHDE RUEHDIR
DE RUEHRH #1987/01 2690942
ZNY SSSSS ZZH
R 260942Z SEP 07
FM AMEMBASSY RIYADH
TO RUEHC/SECSTATE WASHDC 6583
RHEBAAA/DEPT OF ENERGY WASHINGTON DC
INFO RUEHZM/GULF COOPERATION COUNCIL COLLECTIVE
RUEHHH/OPEC COLLECTIVE
RUEAHLC/HOMELAND SECURITY CENTER WASHINGTON DC 0160
RUEATRS/DEPT OF TREASURY WASHDC
RHRMAKS/COMUSNAVCENT
RUEAWJA/DEPT OF JUSTICE WASHDC
RHMFISS/HQ USCENTCOM MACDILL AFB FL
RUEKDIA/DIA WASHINGTON DC
RUCPDOC/DEPT OF COMMERCE WASHDC
RUEAIIA/CIA WASHDC
RHEHNSC/NSC WASHDC
RUEKJCS/SECDEF WASHDC
S E C R E T SECTION 01 OF 09 RIYADH 001987 

SIPDIS

SIPDIS

DEPT OF ENERGY PASS TO A/S KKOLEVAR, A/S KHARBERT, AND
MWILLIAMSON
S/CT FOR GFEIERSTEIN AND BAVERILL
DS/ATA FOR KMALOY
TREASURY PASS TO A/S CLOWERY
DHS PASS TO TWARRICK AND DGRANT
CIA PASS TO TCOYNE

E.O. 12958: DECL: 09/26/2017
TAGS: KCIP EPET ENERG PTER ASEC SA
SUBJECT: JOINT WORKING GROUP ON CRITICAL INFRASTRUCTURE
MEETS IN RIYADH

REF: RIYADH 1954

Classified By: A/DCM David Rundell for reasons 1.4 (b) (c) and (d).

S E C R E T SECTION 01 OF 09 RIYADH 001987

SIPDIS

SIPDIS

DEPT OF ENERGY PASS TO A/S KKOLEVAR, A/S KHARBERT, AND
MWILLIAMSON
S/CT FOR GFEIERSTEIN AND BAVERILL
DS/ATA FOR KMALOY
TREASURY PASS TO A/S CLOWERY
DHS PASS TO TWARRICK AND DGRANT
CIA PASS TO TCOYNE

E.O. 12958: DECL: 09/26/2017
TAGS: KCIP EPET ENERG PTER ASEC SA
SUBJECT: JOINT WORKING GROUP ON CRITICAL INFRASTRUCTURE
MEETS IN RIYADH

REF: RIYADH 1954

Classified By: A/DCM David Rundell for reasons 1.4 (b) (c) and (d).


1. This message has been cleared by DOE A/S Kolevar.

--------------
Summary
--------------


2. (S) On September 11, the US-Saudi Joint Working Group
(JWG) on Critical Infrastructure Protection (CIP) met
at the Ministry of Interior (MOI) in Riyadh, co-chaired by
the MOI Director of Modernization Dr. Saud al-Semari,
and the US Embassy's Economic Counselor Robert Barry Murphy.
Ministry of Interior Special Advisor and
Chief of Staff to Assistant Minister of Interior Prince
Mohammed bin Nayif, Major General Dr. Saad al Jabri
stressed the need for KSA to have contingency planning in
place immediately for continued oil operations
in the event of a terrorist or attack by a neighboring state.
He asked the USG to begin to provide resources
"as early as the next day" to address contingency planning
issues. In addition, the JWG members reviewed
June and September site assessment visits to key energy
installations, and discussed proposed training
curriculums for both the MOI and industrial security to be
conducted by Sandia Labs and the Coast Guard.
The JWG approved conducting a training needs assessment for
the recently-established Facilities Security
Force. The JWG briefly reviewed the status of a training
funding mechanisms currently in the legal approval
process, and approved in principal the establishment of
technical committees as required on an ad hoc basis.

--------------
Meeting Participants
--------------


3. (C) On the Saudi side, meeting participants included:

-- Dr. Saud al Semari, MOI Director of Modernization and JWG
Co-Chair
-- Major General Dr. Saad al Jabri, Special Advisor and Chief
of Staff to Assistant Minister of Interior

Prince Mohammed bin Nayif
-- Col. Saad al Ghamdi, MOI, Facilities Security Force (FSF)
-- Col. Mohammed Raddadi, MOI, Coast Guard
-- Fahad al Nefai, MOI, Mubahith
-- Major Abdullah al Moaner, MOI, Mubahith
-- Capt. Bandar al Subaie, MOI, Personal Assistant to Dr. al
Jabri
-- Abdullah al Shamrani, MOI, Head of Technical Planning,
Department Civil Defense


On the US side, meeting participants included:

-- Robert Barry Murphy, Embassy, Counselor for Economic
Affairs and JWG Co-Chair
-- Kevin Kolevar, Assistant Secretary, Department of Energy,
Office of Electricity Delivery and Energy Reliability
-- Bruce Averill, Department of State, Senior Coordinator for
Critical Infrastructure Protection
-- Shannon Ross, Embassy, Energy Attache
-- Kevin Maloy, Diplomatic Security/Anti-Terrorism Assistant
Office
-- Captain Don Grant, US Coast Guard
-- Kevin Brown, Commander, US Coast Guard
-- Randy Rhodes, US Coast Guard
-- Richard Pacheco, Embassy, Economic Officer

RIYADH 00001987 002 OF 009


-- Bassem Houssami, ConGen Jeddah, Pol/Econ Chief
-- Pat Willging, Department of Energy
-- Sarah Magruder, Department of Energy
-- Rachael Beitler, Department of Energy
-- Byron Gardner, Sandia National Laboratories
-- Dominic Martinez, Sandia National Laboratories
-- Guy Jones, Sandia National Laboratories
-- Tommy Goolsby, Sandia National Laboratories
-- Tim Malone, Sandia National Laboratories
-- Ahmed Abdullat, Embassy, Department of Homeland Security
-- Patrick Gillis, Embassy, Army Attache
-- Joel Wiegert, Embassy, Political Military Affairs
-- Capt. Fink, US Military Training Mission (USMTM) Naval
Forces Division Chief
-- Col. Hall, US Military Training Mission (USMTM) Marine
Forces Division Chief

--------------
MOI Outlines Threats to the Energy Sector;
Saudi MOI Civil Defense Planning
--------------


4. (S) After welcoming remarks by the JWG Co-Chairs and A/S
Kolevar, Abdullah Al-Shamrani, MOI Head of Technical
Planning, Department of Civil Defense, briefed the JWG
participants on the scale and scope of the contingency
planning. He highlighted the possible threats within the
petroleum, refining, petrochemical, power, and related
industries. He noted that Riyadh alone had 1312 such
installations the MOI considered possible terrorist targets,
while acknowledging some were of much greater priority than
others. He outlined the scope of the threat facing energy
facilities, varying from operational error, conventional
explosives, hazardous materials (hazmat),to external threats
from neighboring states. He stressed the Iranian nuclear
threat was the most critical external threat confronting the
oil, power, and petrochemical industries in the region. He
emphasized MOI fears that Iran would recruit agents to carry
out internal sabotage and inflict environmental damage on the
Kingdom.


5. (SBU) Shamrani then outlined the MOI's Civil Defense
institutional structure, authorized by the 1986 Civil Defense
Act, and headed by the Civil Defense Council, with the
Minister of Interior as its lead. The General Directorate of
Civil Defense coordinates efforts of the MOI and volunteers,
and implements emergency management tasks. The General
Administration of Civil Protection works to provide food,
essential medical services, and disaster recovery. During
emergencies, Shamrani indicated the MOI coordinates closely
with the Ministries of Health, Defense, the Red Crescent, and
municipalities. The MOI carried out planning for pre,
during, and post emergency management phases. The MOI places
a large emphasis on controlling hazmat threats, due to the
large number of petroleum and petrochemical industries in the
KSA, and on plans for water provision, due to the KSA's
water-limited environment.

--------------
Moving Ahead on Contingency Planning
--------------


6. (SBU) Kevin Kolevar, the Department of Energy's
Assistant Secretary for Electricity Delivery and Energy
Reliability (DOE/OE),opened the US contingency planning
presentation by noting he was pleased the US and Saudi models
had much in common. For a Saudi audience accustomed to the
energy sector being held in state hands, A/S Kolevar
explained the US energy industry is entirely private.
Nonetheless, he noted, government and the private sector
cooperate in contingency planning, and regularly review their

RIYADH 00001987 003 OF 009


plans to decide if they are the most effective possible.
Kolevar outlined national, regional, and local level
responses, stating that the manner in which we prepare
emergencies in the energy sector is relevant for other
sectors as well.


7. (C) A/S Kolevar then laid out a USG proposal for a
series of contingency planning workshops and training classes
to better prepare the Saudis for a terrorist incident. These
could include Federal Emergency Management Agency (FEMA) or
Department of Homeland Security (DHS) first-responder
training, up through workshops for senior management. The
workshops could be held in the US or the KSA, as appropriate
to the situation.

--------------
The DOE Contingency Planning Model
--------------


8. (SBU) Pat Willging, DOE/OE Senior Energy Security
Advisor, then presented DOE/OE's role in contingency planning
for the US power and energy industry. He first noted that
security measures decrease vulnerability to an attack, while
contingency planning mitigates consequences when an attack
occurs. Both are needed to ensure the continuity of business
and operations. Willging emphasized that in the spectrum of
resiliency of capability, plant managers must carefully
balance both redundancy and recoverability of operations.


9. (SBU) Willging highlighted the partnership between
government and industry for contingency planning and disaster
response. Government responsibilities include continuity and
response planning, while industry responsibilities include
operational continuity and response planning. Both
government and industry have a shared responsibility for
coordination, exercising, and putting their plans into
action. Willging also emphasized the need for a strong
inter-agency effort to keep the energy sector functional in
the event of an emergency. For example, energy sector
personnel require functional roads and water systems to
operate plants. He underscored the need for the energy
sector to understand their most critical pieces of equipment,
and not to confuse these with their most expensive or
profitable pieces of equipment. The most critical equipment
should enjoy the highest level of protection.

--------------
Importance of Disaster Planning and
Exercising as an On-Going Process
--------------


10. (SBU) Willging pointed out that exercising for
disasters is key, stating he personally spends 2-3 months a
year simulating disasters with federal, state, local, and
industry partners to ensure disaster response plans could be
properly executed. He underscored industry utilizes
personnel accountability processes to ensure key personnel
and their families are fully supported during disasters, so
that the personnel can focus on their jobs - restoring key
power, refinery, and other facilities - without distraction.


11. (SBU) Willging advised frequent comprehensive plan
reviews are needed, with 18 months at most between plans, due
to changing conditions on the ground. He advocated
government and industry engage in gap analyses, for example,
to clarify which government or industry actor properly has a
specific area of responsibility. He advised mitigation
planning and table top exercises are the next steps in the
cycle. Willging wrapped up by highlighting that the cycle of
comprehensive plan reviews, gap analysis, mitigation
planning, and tabletop exercises is continuous; when

RIYADH 00001987 004 OF 009


government and industry have completed one cycle, they should
begin another.

-------------- ---
Government Can Help Ensure Clear Communication,
Industry as Partners in Recovery
-------------- ---


12. (C) Abdullah Shamrani, MOI Civil Defense, stated the
Civil Defense division does not have the industry knowledge
necessary to control an accident in a refinery or other
energy facility; they would need industry people to do this.
Kolevar responded by noting that the US had learned valuable
lessons in responding to hurricanes in recent years,
including cases in which the US responses had failed. He
stressed the importance overcoming institutional barriers to
communication. Working with DHS, DOE has re-vamped
communication with other agencies. Most key communication
barriers were organizational in nature, but some were
technical. For example, DOE was working on how to ensure
communications coverage in hurricane-affected areas.


13. (C) A/S Kolevar stated DOE has also worked closely with
industry to emphasize that government must know the status of
critical facilities and casualties. Industry has recognized
neighboring industries matter a great deal more than
previously thought. While they may normally be competitors,
during an emergency, they are partners in recovery, for
example, sharing assets and personnel to move fuel to
first-responders.


14. (C) A/S Kolevar spoke about the appropriate role of
government in an emergency situation, stating, "we do not own
the assets, and companies will move out on their own to
repair their facilities. The appropriate role of government
is to facilitate, clearing roads, facilitating food and water
delivery." He noted that DOE has at times exercised a
stronger role in the national interest, for example, by
directing the restoration of power services to a critical
facility. Kolevar cautioned, however, such action is often a
blunt instrument, which may cause other unintended
difficulties. Coast Guard Rhodes cautioned that
first-responders often were not trained to enter facilities
where terrorists may still be carrying out their attack. At
the same time, military or security forces who could respond
to this threat may lack protective gear and training to enter
a facility which has been attacked by a biological or
chemical agent.

--------------
Offer of Scenario Planning Workshops
--------------


15. (C) A/S Kolevar stated both US industry and government
conduct frequent scenario planning exercises, to prepare for
possible events such as hurricanes, terrorist attacks,
chemical/biological attacks, etc. Kolevar stated, "we would
welcome the opportunity to look at this with you," offering
MOI the opportunity to work with DOE in a scenario planning
workshop. He noted DOE's experience during Hurricanes Rita
and Katrina, prior to which DOE and industry had simulated
the loss of 2 of 14 pumping stations on the key East coast
Colonial pipeline. Instead, both hurricanes took out 7
pumping stations, an unprecedented situation. A/S Kolevar
noted DOE and industry today regularly exercise the loss of
50% of pumping capacity, while appropriate modifications have
been made to the pumping infrastructure to make such an
occurrence less disastrous in the future.


16. (C) Dr. Khalid al Ageel, from the HCIS, stated that,
"we need information on shut-down and prioritization schemes,

RIYADH 00001987 005 OF 009


shut-down procedures, and evacuation from platforms. Can DOE
help us with this?" A/S Kolevar responded positively, and
said he was encouraged to hear the Ministry of Petroleum and
Saudi Aramco would also brought into this discussion, as they
could supply technical information key to these types of
discussions.

--------------
Eastern Province Site Assessment Visits
March, June 2007
--------------


17. (C) Moving to the assessment portion of the agenda,
DS/ATA Maloy quickly re-capped the March land-based
assessment visit to Ras Tanura, Qateef Junction, and Abqaiq
Plants for the benefit of those who had not been
present at earlier JWG meetings. He noted:

Positive Observations:

--Industrial security force preparedness has improved since
initial assessments. Safety and security standards,
and the evacuation procedures are in good shape.

-- Overall physical security has improved with the
instillation of pipe barriers and perimeter vehicle barriers.

Areas of Concern:

--There is limited integration of security forces. Planning
and training exercises need to be a joint effort
with integrated control centers to help improve
communication.

-- The DBT process needs to be better implemented at the
sites. Performance based security upgrades should
be implemented.



18. (C) US Coast Guard Capt. Don Grant briefed on the
Eastern Province (EP) Maritime site assessments conducted
in June 2007. This assessment surveyed maritime-side
critical energy infrastructure in the EP (Ras Tanura and
Ras al Juaymah),and reviewed Coast Guard capabilities and
procedures to detect, delay and interdict a terrorist
threat to these facilities. Grant indicated that in general
he was pleased with the preparedness of
the security forces. Capt. Grant highlighted positive areas
and areas for improvement as follows:

Positive Observations:

-- The EP has a highly regulated fishing and recreational
boating operations.

-- Aramco and the Coast Guard have extensive human visual
detection of threats.

-- There are frequent Aramco aircraft on patrol.

-- There are high port security standards.

Areas of Concern:

-- There was a need for more specific and consistent
identification of critical components within
Ras Tanura and Ras al Juaymah.

-- Maritime Domain Awareness (MDA) AIS was not integrated
with radar.


RIYADH 00001987 006 OF 009


-- There was no Coast Guard presence in Port Control.

-- Responding Forces (Aramco/FSF/Coast Guard) have limited
direct tactical communication.

-- No Blue Force Tracking for Coast Guard.

--------------
Yanbu Consultation Visit, September 2007
--------------


19. (C) DS/ATA Maloy provided an overview of the September
2007 visit to Yanbu Industrial City, and Sandia
Labs Martinez conducted the land side briefing. The Yanbu
Royal Commission provided an overview briefing and
orientation tour for the team. The team then conducted a
pre-assessment of the capabilities of security forces
at Yanbu to detect, delay, and interdict a terrorist threat
at six sites: the Yanbu Port Authority; Sabtank,
a maritime petrochemical loading facility; Ibn Rashd, a SABIC
acetic acid production facility; YANPET, a
SABIC/ExxonMobil joint venture petrochemical plant; and
SAMREF, a Saudi Aramco/ExxonMobil joint venture refinery.
The team viewed access control points, security systems along
the perimeter, and security and process control
rooms as part of their overview. In these Yanbu facilities,
the team observed good industrial security
practices. However, security was not adequate to meet the
terrorist threat defined in the June design
basis threat (DBT) workshop.

Positive observations:

--The security forces are integrated. There is communication
between the forces on procedures and planning.

-- A continuous row of concrete barriers has been or is being
installed around the entire industrial complex. Each
industrial facility has a continuous fence with razor wire or
barbed wire outriggers around the perimeter.

-- Most of the facilities had two lines of detection along
the perimeter, with lights and CCTV cameras.

-- There appeared to be good communication between the
industrial security forces, FSF, and operators within
each of the security control centers. Security forces where
equipped with two-way radios and land lines.

Areas of concern:

-- There are minimal internal delay barriers.

--The current security systems in place at the Yanbu
Industrial sites does not meet the new high level
threat developed during the June 2007 DBT workshop. A
vulnerability assessment for each facility should
take place using the June 2007 DBT.

--There is no armed helicopter interdiction capability.


20. (C) The JWG team generally noted the Yanbu facilities
seemed to enjoy better integration between industrial
security, the FSF, the Coast Guard, and Border Guard than
observed in the Eastern Province. Our Saudi counterparts
explained the western region has less divisive tribal
influences, and a generally more cooperative atmosphere.
Additionally, the Yanbu Royal Commission appears to have
allow the various industries and agencies a structure and
forum for collaborating. The interlocutors noted that the
influence of Saudi Aramco, so dominant in the Eastern

RIYADH 00001987 007 OF 009


Province, is noticeably less in Yanbu, apparently also
leading to greater cooperation on the security front.


21. (C) USCG Captain Grant presented the maritime
observations for the September 2007 Yanbu visit, summarized
below:

Positive observations:

-- There was a Coast Guard presence in the Port Control Tower.

-- Maritime Domain Awareness (MDA): Radar was integrated with
AIS displays at Port control.

-- There were high Port Security Standards.

Areas of Concern:

-- There was a need for more specific and consistent
identification of critical components within the crude oil
and refined product berths (as in the Eastern Province).

-- MDA: Coast Guard lacks Blue Force Tracking.

-- Coast Guard patrolling with weapons mounted and loaded is
mission-dependent.

-- Coast Guard lacks armed helicopter interdiction capability.

-- Responding Coast Guard forces have limited direct tactical
communications.

-- Coast Guard practices limited field training and exercises.

-- Coast Guard has no positive control boarding teams for
large commercial vessels.

USMTM) representative Capt. Fink added that NAVCENT was
training the Royal Saudi Naval Forces (RSNF) in interdiction
capability. Coast Guard Col. Raddadi added that the Saudi
Coast Guard had carried out several exercises since the last
JWG meeting had made recommendations to that effect, its
teams becoming more effective with each subsequent exercise.


--------------
Ramping Up Training for the
Facilities Security Force
--------------


22. (SBU) Sandia Labs Byron Gardner presented a briefing on
the Sandia Labs training curriculum for MOI management,
stressing that it is designed to help them build a
performance-based security system. Gardner reviewed the
content and intended audiences for courses which we plan to
implement for both the industrial security forces and the MOI
over the next several months.


23. (S) The discussion then turned the new Facilities
Security Force which the MOI is recruiting for the protection
of critical installations, such as energy, power, and water
sites. Dr. al Jabri indicated the MOI has recruited 8000 new
FSF soldiers this year, and plans to recruit 10,000 by year's
end. Dr. al Jabri stated the Assistant Minister of Interior
Prince Mohammed bin Nayif had discussed FSF recruitment and
training with Vice-President Cheney, and Cheney had agreed
the US would support the Kingdom in providing equipment and
training for the FSF.


24. (C) Dr. al Semari provided an overview of training
being provided to the FSF currently, through Pakistani

RIYADH 00001987 008 OF 009


military and other international involvement. Sandia Labs
Guy Jones then presented a proposal for a 2-week Training
Needs Assessment for the FSF, to be conducted both in Riyadh
and on the ground at the temporary FSF training site in
Mecca. The proposal was well-received, and was approved.
Sandia Labs Gardner stated Sandia was prepared to begin
training cooperation immediately. Dr. Saad pointed out the
need to resolve funding mechanisms quickly, to allow FSF
training cooperation to begin in earnest. The interlocutors
concluded that S/CT Averill would be responsible for
shepherding through the final conclusion of the funding
documents. JWG Co-Chairs Dr. al Semari and Robert Murphy
agreed to meet weekly.

--------------
Progress on DBT Policy Document
--------------


25. (C) Dr. Khalid al Ageel reported on the progress of the
adoption of the design basis threat (DBT) policy document
since the June DBT workshop conducted by Sandia Labs. Dr.
al Ageel noted the document classified critical facilities
throughout Saudi Arabia (petroleum, water, power, and
petrochemical facilities) as Tier, I, II, and III. Since
July, the document had been translated, and circulated among
the HCIS and intelligence communities. However, SAG
consultants were still reviewing the document, and it was
unclear when it would be adopted as a national policy
document. On a separate but related track, al Ageel noted
that the MOI's High Commission on Industrial Security (HCIS)
would promulgate new industrial security standards next
month, which for the first time would attempt to incorporate
anti-terrorism standards. (Note: The MOI's HCIS is
responsible for writing and implementing industrial security
standards for firms in key sectors such as energy,
petrochemicals, water, and power, until now all largely
state-controlled sectors. New draft industrial security
standards have been in circulation and revision for more than
a year. End note.)

--------------
Moving Ahead to the Next JWG;
Deepening the JWG Organization Structure
--------------


26. (C) Dr. Saud al Semari opened the discussion on the
structural development of the JWG, remarking on the need for
increased administrative support for the JWG on both the
Saudi and US sides, as tasks and commitments become more
complex. He proposed December for the next JWG, and
indicated, "our highest priority is contingency planning" for
this meeting. The JWG members agreed that the Co-Chairs
could designate committees as needed on an ad-hoc basis to
handle specific technical issues, e.g., contingency planning,
training, etc.

--------------
Frangible Ammunition
--------------


27. (C) Sandia Labs' Guy Jones conducted a discussion of
frangible ammunition. He stated that several US
manufacturers make this type of ammunition, which turns to
powder when it strikes hard surfaces, minimizing possible
damage to petroleum facilities. However, it remains
extremely effective against human adversaries. Jones urged
the MOI to invest in performance testing of the ammunition,
as with all new equipment to be deployed at critical
facilities.

-------------- --------------

RIYADH 00001987 009 OF 009


Dr. al Jabri Underscores Threat to Energy Industry
-------------- --------------


28. (S) During the JWG meeting, Dr. Saad al Jabri, the
senior MOI official present, continued to reiterate the
threat facing the Saudi energy industry. He stated, "We are
facing a serious threat. This is an urgent matter and we
must act now. We have identified more than twenty
nationalities involved in the terrorist threat against us.
The threat has not relented, we are just seeing a new type of
threat. All plans are now targeting the oil industry. I
cannot emphasize enough the gravity of the situation."
Reflecting on the state of Saudi contingency planning, al
Jabri admitted their plans are not complete or comprehensive.
He expressed concern that the attack on Abqaiq is a
prototype of what could happen next.

--------------
Comment
--------------


29. (S) In our assessment, Dr. al Jabri is fully on target
to be gravely concerned that the Saudi MOI has not fully
addressed contingency planning for petroleum operations in
the event of a serious terrorist incident or attack by a
neighboring state. This JWG meeting was our first
opportunity to see the MOI's own baseline "contingency
planning" efforts. Unfortunately, these plans dealt almost
exclusively with civil defense aspects of an industrial
accident or attack, focusing on the security and health of
the population. While civil defense planning is a core
governmental function, the MOI does not appear to have begun
to grapple with Dr. al Jabri's principal concern, what DOE
would term "resiliency of capability" of petroleum and other
critical installations in the face of Iranian attack or
internal sabotage. Fortunately, MOI is openly requesting
assistance to address this serious gap.

FRAKER