Kimberly Denbow Vice President, Security & Operations American Gas Association

Some versions of these exclusions may place the owner/operator in the position of not only having to demonstrate the impact of the cyber incident but also to identify the origin and motive of the adversary – the latter action is beyond the practical scope of natural gas utility cybersecurity programs and sometimes even beyond the capability of our federal partners. [...] • Operational Resilience The operational characteristics of the natural gas transportation network in combination with the physical properties of natural gas effectively minimize the likelihood and severity of widespread service disruptions. [...] o Operators manage the internal pressure of the delivery system by controlling the amount of natural gas that enters and leaves the system; this process of increasing and decreasing pressure happens relatively slowly because of the compressibility 7 Members of the DNG-ISAC include AGA member natural gas utilities, transmission pipeline members of the Interstate Natural Gas Association of America,. [...] Despite the challenges associated with the first generation of pipeline Security Directives (SDs) in 2021, the credibility established between TSA and owner/operators prior to the issuance of the SDs helped promote the improvements to subsequent SDs. [...] The inadequate cybersecurity measures that resulted in the breach underscore the need for the government to have stringent safeguards and robust incident response protocols on the systems the government relies on to store critical infrastructure information.