Administrator Pekoske,
The included pipeline trade associations, AFPM, AGA, AOPL, API, APGA, INGAA, and GPA Midstream appreciate the opportunity to engage with TSA in the next phase of pipeline cybersecurity regulations. These trade associations represent almost all aspects of U.S. energy pipeline operations that serve customers reliably across North America. The associations’ members represent refineries and petrochemical operators — through which pipelines receive and distribute products, regional and local natural gas distribution pipelines, liquids pipelines, integrated and midstream natural gas and oil companies, operators of municipal natural gas systems, natural gas transmission pipelines, and natural gas product pipelines and processors.
Across the industry, our members all share the same concerns regarding TSA’s development of pipeline cybersecurity regulations. Both pipeline Security Directives1 are slated to sunset in May and July 2022, respectively. Based on conversations with you and the TSA Surface Operations and Policy sections, we understand TSA intends to pursue formal rulemaking for pipeline cybersecurity to replace the Security Directives. Your remarks to our associations and members this Fall regarding collaboration and process transparency around future rulemaking were well-received. Notably, you welcomed the opportunity for pre-rulemaking meetings with stakeholders and underscored TSA’s intention to have a robust, thoughtful comment period for each phase of the rulemaking process.
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