Comment from AGA, APGA, and NGA (the Associations)

Summary: The American Gas Association, American Public Gas Association, and Northeast Gas Association oppose several aspects of the proposed rule, arguing that it exceeds Congressional intent, imposes unreasonable costs, and sets an unfeasible compliance timeline. They specifically argue that the rule is overly prescriptive regarding threat modeling and that the proposed one-year deadline for significant infrastructure upgrades is impractical for the industry.