Pursuant to the Notice of Proposed Rulemaking (NOPR) issued June 16, 2016 by the Federal Energy Regulatory Commission (Commission) in the above-referenced proceeding,[1] the Interstate Natural Gas Association of America (INGAA) respectfully submits these comments. The NOPR proposes to augment the Commission’s current critical energy infrastructure information designation process to comply with revised Federal Power Act (FPA) section 215A(d) and Congress’ requirements in the Fixing America’s Surface Transportation (FAST) Act. INGAA supports the Commission’s efforts to protect critical energy/electric infrastructure information (CEII) through the NOPR, subject to the comments below. INGAA supports the Commission’s proposal to strengthen its CEII regulations and agrees with the Commission’s imperative to “limit the distribution of sensitive infrastructure information to those individuals with a need to know in order to avoid having sensitive information fall into the hands of those who may use it to attack the nation’s infrastructure.”[2]
[1] Regulations Implementing FAST Act Section 61003 – Critical Electric Infrastructure Security and Amending Critical Energy Infrastructure Information, 155 FERC ¶ 61,278 (2016).
[2] NOPR at Par. 9.
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