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DHSNonrulemakingDHS-2006-0073

Chemical Facility Anti-terrorism Standards

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Last modified
Jan 30, 2023
Comment window
closed 6453d ago
American Gas Association filings
2

Activity

American Gas Association filed 2 comments on this docket between Feb 7, 2007 and Dec 1, 2008. 211 other organizations filed here. The comment window closed 6453d ago.

What American Gas Association filed (2)

Dec 1, 2008· Comment Submitted by Kimberly Denbow, American Gas Association (AGA)· DHS-2006-0073-1390

AGA Comments to Docket DHS-2006-0073

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Feb 7, 2007· Comment Submitted By Gary W. Gardner, American Gas Association· DHS-2006-0073-0046

The American Gas Association (AGA) appreciates the opportunity to comment on the Chemical Facility Anti-Terrorism Standards ? Proposed Rule that was issued on December 28, 2006 (Federal Register Vol. 71, No. 749). AGA and its natural gas utility members support DHS? efforts to protect our nation?s critical infrastructure. Upon review of the proposed rulemaking, AGA would like to submit the comments below for consideration: 1.AGA is requesting exemption of natural gas pipelines and facilities from this proposed rule. 2.The security of natural gas pipelines and facilities is currently overseen by the DHS Transportation Security Administration (TSA) as established under HSPD-7 and the Aviation and Transportation Security Act, Pub. L. 107-71, 115 Stat. 597, et seq. (2001). In addition, there is proposed legislation currently before Congress (?Surface Transportation and Rail Security Act of 2007?) that strengthens the DHS (TSA) oversight and includes specific directives regarding security reviews and potential regulation for natural gas pipelines. 3.Specifically regarding natural gas underground storage fields and liquefied natural gas (LNG) facilities, EPA issued a final rule on January 6, 1998, which listed regulated substances and threshold quantities under section 112(r) of the Clean Air Act for accidental release prevention ? requiring the development for each facility a Risk Management Plan (RMP). The final rule modifies the definition of stationary source as listed in 40 CFR Part 68 to clarify the exemption of transportation and storage incident to transportation. 4.The requirements, as such, in Section 550 are duplicative of the active security initiatives as they apply to natural gas pipeline and facility security. We feel strongly that to add natural gas facilities and pipelines under the jurisdiction of the Chemical Facility Anti-Terrorism Standards, considering current oversight of DHS (TSA), Department of Transportation?s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), and Department of Energy (DOE), would be an extreme duplication of effort, result in significant additional costs to both the federal government and the asset owners, and could potentially weaken the ability to secure the critical facilities we are attempting to protect. The full text of AGA's comments is attached.

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Co-filers (211)

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