FNB Gas statement on the draft bill on implementing the CER Directive and strengthening the resilience of critical facilities

The past year and a half has brought to light that the protection of Critical Infrastructure (CIP), especially gas infrastructure, is essential for maintaining economic and social life as well as national security.

In principle, FNB Gas supports the proposal of the Federal Ministry of the Interior and for Home Affairs regarding the draft law on the implementation of the CER Directive and on strengthening the resilience of critical facilities (KRITIS-Dachgesetz – KRITIS-DachG).

In accordance with the requirements of Section 78 para. 1 No. 1 in conjunction with. § 79 para. 1 No. 1 TKG, transmission system operators (TSOs) are required to provide data on the telecommunications structure they operate to the Federal Network Agency’s (BNetzA) Central Information Service (CIS). This data is then published in the Infrastructure Atlas (ISA).

The TSO Gas considers it necessary to avoid the publication of sensitive infrastructure data, which exposes Germany’s critical infrastructure to unnecessary risks, or at least to be more sparing with the publication of such data, unless there is an overriding public interest in the publication of such data.

A corresponding provision could be made by exempting the aforementioned critical infrastructures from the publication requirement under the TKG by reference in the KRITIS-DachG.

The complete statement of the FNB Gas is available in the downloads.