Since 9/11, no new rules or regulations have been promulgated to
address pipeline or LNG facility security or cybersecurity.
Although the Transportation Security Administration (TSA) recently
released an updated version of its "Pipeline Security Guidelines"
(Guidelines) that were last issued in 2011, those Guidelines remain
advisory. And both the Department of Homeland Security (DHS) and
the Federal Bureau of Investigation (FBI) have made only informal
outreach to pipeline and LNG industry as issues have arisen. As the
threat of both cyber and physical attacks on critical energy
infrastructure continues, however, some question whether minimal
standards for prevention of threats should be in place. In
particular, there has been recent attention by the U.S. Government
Accountability Office (GAO), members of Congress, and at least one
Federal Energy Regulatory Commission (FERC) commissioner. (See
E&E News Article of May 29, 2018). These discussions, along
with recent
