Vessel Security Plans

These interim regulations are a good-faith attempt to address business's need for flexibility, coordination among all government agency requirements, and the security of sensitive information. However, there still is not enough sensitivity to the need for: -room for flexible approaches that fully recognize the dramatic differences among various entities and industries that all may have facilities within the purview of the Coast Guard; -clear, simple guidelines that result from coordinating the Coast Guard's requirements with the security and safety requirements of other regulatory and oversight agencies of Federal as well as state government (such as the Nuclear Regulatory Commission), as well as with existing industry security guidelines and standards, with which the utility industry already complies, and coordination of which is already complicated; -and, practical reflection of the fact that there are too many ways by which the general public is able to access sensitive critical infrastructure information once it is given to the government under force of law. While the Coast Guard has been sensitive to these issues, we do still have serious concerns that must be addressed and resolved in order to assure an efficient implementation of effective security procedures by all relevant entities. We suggest that the Coast Guard provide clarification and simplification where it can, and make changes elsewhere. Our goals and the Coast Guard¿s are the same: a truly secure society in which to conduct our affairs. As critical infrastructure providers we are keenly aware how much our society depends upon us. Utilities have traditionally been sensitive to society¿s need for our services, and as a result have traditionally held the provision of reliable, safe energy to be of paramount importance. Thus, we look forward to working closely with the Coast Guard to better address maritime security within the broader context of economic and Homeland Security.