Regulatory Submissions

APGA and a host of other trade associations representing energy, as well as railroad companies, asked for a due date extension of the comment period for a recently proposed rulemaking, “Enhancing Surface Cyber Risk Management.” On November 30, the Transportation Security Administration (TSA) published an advance notice of proposed rulemaking (ANPRM) seeking input regarding ways to strengthen cybersecurity and resiliency in the pipeline and rail sectors. The ANPRM sets forth critical questions to help TSA develop a comprehensive and forward-looking approach to cybersecurity requirements, and to carefully consider the appropriate next step. APGA and the other joint requesters appreciate TSA’s ongoing efforts across the pipeline and rail sectors. Unfortunately, TSA has not provided sufficient time for stakeholders to review and analyze the lengthy ANPRM to develop meaningful comments.

Hopefully, extra time will be granted. Regardless, APGA will be engaging TSA in this ANPRM. The regulator needs to understand that any cybersecurity rules for public natural gas utilities should be practical and fit-for-purpose. The energy supply chain has a variety of processes and operations. A one-size-fits-all approach to regulating cybersecurity is not appropriate. APGA staff will continue to inform the Security Task Group on the progress of this work.