HomeMy WebLinkAboutSouthern California Edison - California Public Utilities Com SOUTHERN CALIFORNIA Gloria M Ing
El
E D I S O N® Senior Attorney
gloria tng@sce corn
An EDISON INTERNATIONALS Company
July 1, 2015
Re California Public Utilities Commission (CPUC) Rulemaking No 15-06-009
To whom it may concern
Pursuant to Ordering Paragraph 10 of the CPUC's June 22, 2015 Rulemaking No 15-06-
009, Southern California Edison Company is serving a copy of the rulemaking on the city and
counties within its California service area
If you have any questions, please contact Gloria Ing at 626-302-1999
Very truly yours,
Is/Gloria M Ing
Gloria M Ing
/gmi
LIMS-253-11767
P 0 Box 800 2244 Walnut Grove Ave Rosemead,California91770 (626)302-1999 Fax(626)302-3990
ALJ/GK1/lt2 Date of Issuance 6/22/2015
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking Regarding
Policies, Procedures and Rules for
Regulation of Physical Security for the
Electric Supply Facilities of Electrical FILED
Corporations Consistent with Public PUBLIC UTILITIES COMMISSION
Utilities Code Section 364 and to Establish JUNE 11, 2015
Standards for Disaster and Emergency SAN FRANCISCO, CALIFORNIA
Preparedness Plans for Electrical RULEMAKING 15-06-009
Corporations and Regulated Water
Companies Pursuant to Public Utilities
Code Section 768 6
ORDER INSTITUTING RULEMAKING TO FULFILL THE REQUIREMENTS OF
PUBLIC UTILITIES CODE SECTIONS 364 AND 768.6
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Table of Contents
Title Page
ORDER INSTITUTING RULEMAKING TO FULFILL THE REQUIREMENTS
OF PUBLIC UTILITIES CODE SECTIONS 364 AND 768.6 1
Summary 2
1 Events Leading to Senate Bill (SB) 699 2
11 Changes to Public Utilities Code Section 364 4
12. Applicable Safety Standards Prior to the Amendment of Section 364
of the Public Utilities Code 5
13. Discussion Pertaining to SB 699 8
2 Events Leading to Assembly Bill (AB) 1650 9
2.2 Emergency and Disaster Preparedness Plans for Electrical
Corporations and Regulated Water Corporations Prior to the
Addition of Public Utilities Code Section 768 6 13
2 3 Discussion Pertaining to AB 1650 14
3 Preliminary Scope. 15
31 Issues to be Considered Pursuant to SB 699 15
3 2 Issues to be Considered Pursuant to AB 1650 16
4 Preliminary Schedule and Initial Comments 17
5 Proceeding Category and Need for Hearing 18
6 Respondents . . ............... 19
7 Service of OIR 19
8 Filing and Service of Comments and Other Documents . .21
9 Addition to Official Service List. 21
10 Subscription Service. 22
11 Public Advisor 22
12 Intervenor Compensation 22
13 Ex Parte Communications 23
Appendix A - Senate Bill 699 amending Public Utilities Code Section 364
Appendix B - Regulation of Physical Security for the Electric Distribution
System, February 2015
Appendix C - Assembly Bill 1650 adding Public Utilities Code Section 768 6
Appendix D - California Publicly Owned Electric Utilities
Appendix E - List of Rural Electric Cooperatives
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Table of Contents (cont.)
Title Page
Appendix F - Publicly Owned Utilities Representatives and Agents
Appendix G - Facilities-Based Communications Carriers Authorized to Operate
in California
Appendix H - Service List of Resolution No W-4823
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ORDER INSTITUTING RULEMAKING TO FULFILL THE REQUIREMENTS OF
PUBLIC UTILITIES CODE SECTIONS 364 AND 768.6
Summary
This rulemakmg is opened to establish policies, procedures, and rules for
the regulation of physical security risks to the electric supply facilities of
electrical corporations consistent with Public Utilities Code Section 3641
This rulemakmg is also opened to establish standards for disaster and
emergency preparedness plans for electrical corporations and regulated water
companies consistent with Public Utilities Code Section 768 62
We will consider whether any new rules, standards, or General Orders
(GO) or modifications to other existing policies should apply to all electrical
supply facilities within the jurisdiction of the Commission, including facilities
owned by publicly-owned-utilities, rural electric cooperatives and regulated
water companies This proceeding will be conducted in phases The first phase
will pertain to the requirements to address the physical security risks to the
electrical supply facilities of electrical corporations Additional phases will be
conducted to address emergency and disaster preparedness plans of electrical
corporations and regulated water companies
1. Events Leading to Senate Bill (SB) 699
The vulnerability of electrical supply facilities has been demonstrated in
recent years by attacks In April 2013, a rifle attack occurred at Pacific Gas and
1 Section 364 of the Public Utilities Code was amended by Senate Bill 699 (Stats 2014, ch 550,
Sec 2)
2 Section 768 6 of the Public Utilities Code was added by Assembly Bill 1650 (Scats 2012,
ch 472)
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Electric's (PG&E) Metcalf Transmission Substation south of San Jose, resulting in
approximately $15 4 million in damages Although PG&E initiated various
changes in its security protocol, in late August 2014, burglars entered the Metcalf
facility and removed $38,651 of tools and equipment 3
Regulatory jurisdiction over transmission facilities and substations is
shared between federal and state agencies The Federal Energy Regulatory
Commission (FERC) is an independent federal agency that regulates the
interstate transmission of electricity, including the "Bulk-Power System" and
related facilities that include some high voltage transmission facilities and
substations 4
Several grid security guidelines or standards have been proposed or
developed to address the physical security of the electrical supply facilities of
electrical corporations. However, prior to the Metcalf incident, many of these
standards were considered as voluntary best practices. Following the Metcalf
incident, FERC ordered the imposition of mandatory physical security standards
to be prepared by the North American Electric Reliability Corporation (NERC) 5
In California, SB 699 was enacted to ensure that steps would be taken to
reasonably protect electrical supply facilities of electrical corporations against
further attacks 6
3 PG&E Metcalf Root Cause Analysts Summary Report November 21, 2014 at 2
4 Http //www ferc gov
5 NERC is a not-for-profit international regulatory authority whose mission is to ensure the
reliability of the bulk power system in North America See,http //www nerc com
6 The Commission does not expect anything in this rulemakmg to conflict with any FERC or
NERC regulations,jurisdiction, or proceedings
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1.1 Changes to Public Utilities Code
Section 364
SB 699 amended Section 364 of the Public Utilities Code to require that the
Commission "in a new proceeding, or new phase of an existing proceeding, to
commence on or before July 1, 2015, consider adopting rules to address the
physical security risks to the distribution systems of electrical corporations "
Additionally, this legislation provides that the Commission may, "consistent
with other provisions of law, withhold from the public information generated or
obtained pursuant to this section that it deems would pose a security threat to
the public if disclosed " This rulemaking is concerned with implementing the
amendments to Section 364 of the Public Utilities Code
Prior to SB 699, Section 364 of the Public Utilities Code provided the
following
1 Requires the Commission to adopt inspection, maintenance,
repair, and replacement standards for the distribution facilities
of investor-owned utilities (IOUs) in order to provide
high-quality, safe, and reliable service
2 Requires the Commission to adopt standards for operation,
reliability, and safety during periods of emergency and disaster
3 Requires each utility to report annually on compliance with the
applicable standards.
4 Requires annual compliance reports submitted by the utility to
be made available to the public
5 Requires the Commission to conduct a review to determine
whether the standards have been met and to perform a review
after every major outage
6 Provides that the Commission may order appropriate sanctions,
"including penalties in the form of rate reductions or monetary
fines "
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7 Any penalties or fines collected shall be used to offset funding
for the California Alternative Rates for Energy Program
As amended by SB 699, Section 364 of the Public Utilities Code added the
following additional requirements
1 Requires the Commission to open a new proceeding or phase of
an existing proceeding by July 1, 2015, to consider adopting
standards or rules to address the physical security risks to the
distribution systems of electrical corporations
2 The standards or rules shall be prescriptive or performance
based, or both
3 The standards or rules may be based on risk management
practices as appropriate, for each substantial type of distribution
equipment or facility
4 The standards or rules shall provide for high-quality, safe, and
reliable service
5 In setting the standards or rules, the Commission shall consider
cost, local geography and weather, applicable codes, potential
physical security risks, national electric industry practices,
sound engineering judgment, and experience
6 Provides that the Commission may, consistent with other
provisions of law, withhold from the public information
generated or obtained pursuant to this section that the
Commission deems would pose a security threat to the public if
disclosed
Appendix A to this rulemaking provides the full text of SB 699 amending
Public Utilities Code Section 364
1.2. Applicable Safety Standards Prior to the
Amendment of Section 364 of the Public
Utilities Code
Section 364 of the Public Utilities Code requires the Commission to adopt
standards for distribution facilities that provide for high quality, safe, and
reliable service Among other things, the Commission has adopted several
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decisions, GOs, and rules to provide the utilities with standards and guidance to
ensure an adequate level of safe and reliable service Pursuant to GOs 95, 128,
131-D, 165, 166, 167 and 174, Commission staff is currently routinely involved in
the verification of the condition and operation of existing physical security
protections Additionally, D 14-12-025 now requires all utilities to discuss safety
and risk assessments in every rate case
The Commission adopted GO 95 in Decision (D ) 34884, dated
December 23, 1941, and has amended GO 95 many times since then GO 95
contains rules for the design, construction, and maintenance of overhead
power lines and communication lines located outside of buildings GO 95 was
last modified by D 15-01-005 on January 21, 2015
The Commission adopted GO 128 in D 73195, dated October 17, 1967, and
has amended GO 128 several times since then GO 128 contains rules for the
design, construction, and maintenance of underground electrical supply systems
used in connection with public utility service and underground communication
systems used in connection with public utility service located outside of
buildings GO 128 was last modified on January 13, 2005, in D.05-01-030
The Commission adopted GO 131-D in D 94-06-014, dated June 8, 1994,
which became effective July 8, 1994 GO 131-D requires that no electric public
utility shall begin construction in this state of any new electric generating plant,
or of the modification, alteration, or addition to an existing electric generating
plant, or of electric transmission/power/distribution line facilities, or of new,
upgraded or modified substations without first obtaining approval from the
Commission GO 131-D was last modified in D 95-08-038 on August 11, 1995,
with the modifications effective on September 10, 1995
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On March 31, 1997, D 97-03-070 adopted GO 165 It was later revised by
D 13-06-011 on June 27, 2013 Among other things, GO 165 established standards
for inspection for transformers, switching/protective devices,
regulators/capacitors, overhead conductor and cables, street lighting, and wood
poles GO 165 also set forth reporting responsibilities and called for the ability of
Commission staff to inspect records of inspections consistent with Public Utilities
Code Section 314(a)
On July 23, 1998, the Commission issued D 98-07-097 to establish GO 166,
which set forth 11 standards for electric service reliability and safety during
emergencies and disasters These standards ensure that utilities are prepared for
emergencies in order to minimize damage and inconvenience resulting from
electric system failures and major outages GO 166 contains detailed
requirements for emergency planning and performance during emergencies, and
requires an investigation following every major outage On May 4, 2000, the
Commission issued D 00-05-022 to add Standards 12 and 13 and to define a
Major Event It was last revised on May 15, 2014, by D 14-05-020
On May 6, 2004, the Commission issued D 04-05-017, adopting GO 167,
which set forth enforcement of maintenance and operation standards for electric
generating facilities GO 167 was most recently modified on November 6, 2008
by D 08-11-009. Section 10 4 of GO 167 sets forth various requirements for
reporting safety related and property damage incidents Section 110 notifies of
the requirement to cooperate with Commission staff during audits, inspections
or investigations
On October 25, 2012, the Commission adopted D 12-10-029 to establish
GO 174 The purpose of GO 174 is to set forth uniform requirements for
substation inspections Among other things, GO 174 requires the inspection of
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perimeter fences and gates and sets forth record keeping and reporting
responsibilities for all inspections performed
In addition to already established standards and procedures listed above,
SB 699 now requires the Commission to develop additional security measures
These additional security measures will help ensure an adequate level of safety
for electrical supply facilities of electrical corporations This rulemaking will be
the procedure that the Commission uses to establish the necessary additional
security measures
1.3. Discussion Pertaining to SB 699
Ensuring the physical security of electrical supply facilities is of great
importance in order to provide high quality, safe, and reliable service In order
to protect the electrical supply facilities of electrical corporations from security
threats, the Commission has decided to undertake rulemakmg on this issue This
rulemaking will provide for the regulatory framework pertaining to the physical
security risks to the electrical supply facilities of electric corporations and will be
consistent with the requirements set forth in SB 699, which amended Section 364
of the Public Utilities Code
The April 2013 attack on the Metcalf Substation, and subsequent new
standards set out by NERC have emphasized the need for standards to ensure
the physical security of the electric grid In California, SB 699 amended Public
Utilities Code Section 364 to require the Commission to address physical security
risks at the electrical supply level via the development of new rules and
standards As a result of SB 699, Commission Staff drafted a whitepaper, which
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was released February 20157 In this paper, Commission staff provides various
recommendations and opinions the Commission may consider during this
rulemaking process s
Among other things, SB 699 requires the Commission to consider local
geography and weather, and applicable codes when setting its standards or
rules Furthermore, SB 699 allows the Commission to consider options that
include the nondisclosure to the public of any sensitive information, that if
disclosed could pose a security threat
Considering the wide possibilities of potential attacks, various equipment
designs, and potential costs of implementing procedures, and rules for the
security of the electrical supply facilities within the various utilities, a "one size
fits all" approach may not be feasible This rulemaking will consider and solicit
input from the utilities and other interested persons on what rules and
procedures should be adopted by this Commission
2. Events Leading to Assembly Bill (AB) 1650
In September 2011, there were widespread outages in the Pacific
Southwest that adversely impacted drinking water supplies due to the lack of
electricity at pumping stations In December 2011, there was a severe wind
7 The whitepaper, titled Regulation of Physical Security for the Electric Distribution System,
February 2015 is attached as Appendix B and is also available at
www cpuc ca gov/NR/rdonlyres/930FCC00-BE2F-4BCF-9B68-2CA2CDC38186/0
/Physical SecurgyfortheUtili lndustry20l50210 pdf
s As indicated in the whitepaper, the views presented in the whitepaper are those of the staff
and do not necessarily represent the views of the five member California Public Utilities
Commission This paper is intended to initiate a dialog on the topics discussed and any
recommendations are preliminary Staff may revise this whitepaper based on further
discussion and any comments received
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storm that caused major damage throughout the San Gabriel Valley, including
the loss of power to thousands of utility customers for a significant period of
time Many utility customers and local governmental entities were not provided
sufficient information from the utilities regarding the status of the power outage
or other damages caused by the windstorm
2.1. Section 768.6 of the Public Utilities Code
AB 1650 added Section 768 6 to the Public Utilities Code to require the
Commission in an existing proceeding to establish standards for disaster and
emergency preparedness plans for electrical corporations and any water
company regulated by the Commission This rulemaking is concerned with
implementing the addition of Section 768 6 of the Public Utilities Code
Section 768 6 requires the following
1 The Commission shall establish standards for disaster and
emergency preparedness plans within an existing proceeding,
including, but not limited to, the use of weather reports to
preposition manpower and equipment before anticipated severe
weather, methods of improving communications between
governmental agencies and the public, and methods of working
to control and mitigate an emergency or disaster and its
aftereffects The Commission, when establishing standards
pursuant to this subdivision, may make requirements for small
water corporations similar to those imposed on class A water
corporations
2 An electrical corporation shall develop, adopt, and update an
emergency and disaster preparedness plan in compliance with
the standards established by the Commission
3 In developing and adopting an emergency and disaster
preparedness plan, an electrical corporation shall invite
appropriate representatives of every city, county, or city and
county within that electrical corporation's service area to meet
with, and provide consultation to, the electrical corporation
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4 Every city, county, or city and county within the electrical
corporation's service area may designate a point of contact for
the electrical corporation to consult with on emergency and
disaster preparedness plans The point of contact shall be
provided with an opportunity to comment on draft emergency
and disaster preparedness plans
5 For the purposes of best preparing an electrical corporation for
future emergencies or disasters, an emergency and disaster
preparedness plan shall address recent emergencies and
disasters associated with the electrical corporation or similarly
situated corporations, and shall address remedial actions for
possible emergencies or disasters that may involve that
corporation's provision of service
6 Every two years, in order to update and improve that electrical
corporation's emergency and disaster preparedness plan, an
electrical corporation shall invite appropriate representatives of
every city, county, or city and county within that electrical
corporation's service area to meet with, and provide consultation
to, the electrical corporation
7 For the purposes of best preparing an electrical corporation for
future emergencies or disasters, an electrical corporation
updating its emergency and disaster preparedness plan shall
review the disasters and emergencies that have affected
similarly situated corporations since the adoption of the plan,
remedial actions taken during those emergencies or disasters,
and proposed changes to the plan The electrical corporation
shall adopt in its plan the changes that will best ensure the
electrical corporation is reasonably prepared to deal with a
disaster or emergency
8 Any meeting between the electrical corporation and every city
and county within the electrical corporations service area shall
be noticed and shall be conducted in a public meeting that
allows for the participation of appropriate representatives of
counties and cites within the electrical corporation's service
area A county participating in a meeting may inform each city
within the county of the time and place of the meeting An
electrical corporation holding a meeting shall provide
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participating counties and cities with the opportunity to provide
written and verbal input regarding the corporation's emergency
and disaster preparedness plan For purposes of this public
meeting, an electrical corporation may convene a closed meeting
with representatives from every city, county, or city and county
within that electrical corporation's service area to discuss
sensitive security-related information in the electrical
corporation's emergency and disaster preparedness plan and to
solicit comment An electrical corporation shall notify the
Commission of the date, time, and location of the meeting An
electrical corporation shall conduct initial meetings no later than
April 1, 2013, and shall conduct meetings every two years
thereafter An electrical corporation shall memorialize these
meetings and shall submit its records of the meetings to the
Commission
9 A water company regulated by the Commission shall develop,
adopt, and update an emergency and disaster preparedness plan
in compliance with the standards established by the
Commission This requirement shall be deemed fulfilled when
the water company files an emergency and disaster
preparedness plan pursuant to another state statutory
requirement A water company developing, adopting, or
updating an emergency and disaster preparedness plan shall
hold meetings with representatives from each city, county, or
city and county in the water company's service area regarding
the emergency and disaster preparedness plan An electrical
corporation or a water corporation may fulfill a meeting
requirement imposed by this section by making a presentation
regarding its emergency and disaster preparedness plan at a
regularly scheduled public meeting of each disaster council
created pursuant to Article 10 (commencing with Section 8610)
of Chapter 7 of Division 1 of Title 2 of the Government Code
within the corporation's service area, or at a regularly scheduled
public meeting of the governing body of each city, county, or
city and county within the service area
Appendix C to this rulemaking provides the full text of AB 1650 creating
Public Utilities Code Section 768 6
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2.2. Emergency and Disaster Preparedness Plans
for Electrical Corporations and Regulated
Water Corporations Prior to the Addition of
Public Utilities Code Section 768.6
Ensuring that electrical corporations and regulated water companies are
adequately prepared during an emergency is of great importance Over many
years, the Commission has implemented disaster preparedness measures by
adopting decisions, industrial standards, GOs, and rules to provide the utilities
with standards and guidance regarding disaster preparedness
As noted above, the Commission issued D 98-07-097 to establish GO 166
GO 166, among other things, requires electric utilities to annually file updated
emergency response plans, including requiring the utility to notify local
governments of its annual emergency response exercise Additionally, GO 166
requires training and planning for deployment of personnel in anticipation of an
event that may result in a major outage However, it does not currently require
deployment of personnel in the event of anticipated severe weather.
GO 103-A became effective on September 10, 2009, with the adoption of
Resolution No W-4823 GO 103-A sets forth various minimum standards for
operation, maintenance, design and construction in regard to regulated water
companies Among other things, GO 103-A requires regulated water companies
to cooperate with the Commission to "promote a reduction in hazards within the
industry and to the public and requires the report of accidents that may disrupt
the supply of water or impact continuity of service "
In order to ensure that electrical corporations and regulated water
companies are sufficiently prepared for an emergency or other disaster, the
Commission has undertaken various actions to provide guidance in preparing
for a disaster or emergency GOs 166 and 103-A provide utilities with basic
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guidance in preparing for emergencies and other disasters, but does not provide
all of the requirements set forth in AB 1650 AB 1650 helps to provide additional
guidance in preparing for natural disasters and other emergencies AB 1650
requires that the Commission undertake rulemaking to provide further guidance
and sets forth various requirements that electrical corporations and regulated
water companies must comply with to ensure that these utilities are adequately
prepared for an emergency or other disasters
2.3. Discussion Pertaining to AB 1650
Ensuring that utilities are adequately prepared for emergencies and other
disasters is of great importance in order to provide high quality, safe, and
reliable service In order to ensure that regulated utilities are sufficiently
prepared to deal with emergencies and other disasters, the Commission is
opening this rulemaking to provide for the regulatory framework concerning
emergency and disaster preparedness plans that regulated utilities shall adopt in
order to be better prepared for disasters and other emergencies
With input from the public and local agencies, the Commission will ensure
electric corporations and regulated water companies have emergency
preparedness plans that will be better able to help protect the public from
disruption in electricity and water supply during emergencies or other disasters
and consistent with the requirements of Section 768 6 to the Public Utilities Code
Part of this rulemaking is to solicit input from the utilities and other interested
persons on what rules and procedures should be adopted by this Commission
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3. Preliminary Scope
As required by the Commission's Rules of Practice and Procedure
Rule 71(d), this order irutiating the rulemaking includes a preliminary scoping
memo as set forth below 9 The purpose of this rulemaking is to establish new
rules and standards and to update existing requirements regarding the physical
security of electrical supply facilities, in a manner which is consistent with SB 699
and to ensure that electrical corporations and regulated water companies have
adequate disaster and emergency preparedness plans in effect that are consistent
with AB 1650
3.1. Issues to be Considered Pursuant to
SB 699
The issues to be considered in this proceeding related to SB 699 may
include, but are not limited to the following
1 What are the key potential physical security risks to
electrical supply facilities?
2 What new rules, standards, or General Orders or
modifications to existing policies should the Commission
consider to mitigate physical security risks to electrical
supply facilities?
3 Should any new rules, standards, or General Orders or
modifications to existing policies apply to all electrical
supply facilities within the jurisdiction of the Commission,
including facilities owned by publicly owned electrical
utilities and rural electric cooperatives?
4 Are there other factors not listed in Section 364(b) of the
Public Utilities Code that the Commission should consider
when adopting any new rules, standards, or General
9 All references to Rules are to the Commissions Rules of Practice and Procedure
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Orders or modifications to existing policies during this
rulemaknng?
5 What new rules or standards or modifications to existing
policies should the Commission consider to allow for
adequate disclosure of information to the public without
disclosing sensitive information that could pose a security
risk or threat if disclosed?
6 What is the role of cost and risk management in relation to
the mitigation of any potential security risks to electrical
supply facilities?
7 Should any new rules, standards, or General Orders or
modifications to existing policies the Commission
considers be prescriptive or performance based, or both?
8 What new rules, standards, or General Orders or
modifications to existing policies should the Commission
consider to ensure continued operation, reliability and
safety during periods of emergencies and disasters as it
relates to security of electrical supply facilities?
3.2. Issues to be Considered Pursuant to
AB 1650
The issues to be considered in the subsequent phases of this proceeding
under AB 1650 may include, but are not limited to the following
1 What elements should be included in the electrical
corporations' and regulated water companies' emergency
and disaster preparedness plans?
2 What new rules, standards, or General Orders or
modifications to existing policies should the Commission
consider to ensure that electrical corporations and
regulated water companies are in compliance with the
statutory requirements of Public Utilities Code
Section 768 6?
3 Should any new rules, standards, or General Orders or
modifications to existing policies apply to all electrical
supply facilities within the jurisdiction of the Commission,
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including facilities owned by publicly owned electrical
utilities and rural electric cooperatives?
4 Should the requirements for small water corporations be
similar to those imposed on Class A water companies?
5 Should any new rules, standards, or General Orders, or
modifications to existing policies be adopted to ensure
that counties and cities have an opportunity to participate
in the preparation of emergency and disaster
preparedness plans?
4. Preliminary Schedule and Initial Comments
Public Utilities Code Section 1701 5(a) provides that in a quasi-legislative
proceeding, the Commission shall resolve the issues raised in the scopmg memo
within 18 months of the date the scoping memo is issued However,
Section 1701 5(b) provides that the assigned Commissioner may specify in the
scoping memo a resolution date of more than 18 months if the scopmg memo
includes specific reasons for the necessity of a later date
Due to the complexity of this rulemaking, the number of respondents
involved, the number of diverse issues presented, and the potential need for
multiple phases, this matter will not be able to be concluded within 18 months
Therefore, it is preliminarily determined pursuant to Section 1701 5(b) that Phase
I of this proceeding should be resolved within 24 months
As noted above, this Order Instituting Rulemakmg (OIR) will be
conducted in phases Phase I will pertain to the requirements imposed on
electrical corporations by SB 699 Additional phases of this order instituting
rulemakmg will pertain to the requirements imposed on electrical corporations
and regulated water companies pursuant to AB 1650
The preliminary schedule for this proceeding is stated below in Table 1
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Table 1
Are the Questions set forth above in the Preliminary
30 days from Issuance of Scope the Appropriate Questions to Consider? Should
this OIR the Commission Consider Additional Questions? Are
there Other Issues in this Proceeding that the
Commission Should Consider?
TBD Prehearing Conference on Phase I issues
TBD Scoping Memo on Phase I issues, and on final category
and hearing determinations
TBD Workshop(s) as needed on Phase I issues
TBD Comments on Issues Presented at Workshop(s)
TBD Reply to Comments from Workshop(s)
24 Months from Issuance of
Proposed Decision on Phase I issues
Scopmg Memo
A complete schedule for later phases of this proceeding will be set by later
rulings of the assigned Commissioner or Administrative Law Judge
5. Proceeding Category and Need for Hearing
Rule 71(d) specifies that an OIR will preliminarily determine the category
of the proceeding and the need for hearing As a preliminary matter, we
determine that this proceeding is quasi-legislative as defined in Rule 13(d) It
appears that the issues may be resolved through comments and workshops
without the need for evidentiary hearings In the event that an evidentiary
hearing becomes necessary, the assigned Commissioner or Administrative Law
Judge will issue a ruling that sets forth the process that will be used, and the
schedule to be followed
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Any person who objects to the preliminary categorization of this
rulemaking as quasi-legislative or to the preliminary hearing determination shall
state any objections and material facts they believe require a hearing in their
responses to the questions herein After considering any comments on the
preliminary categorization or preliminary hearing determination, the assigned
Commissioner will issue a scoping ruling making a final category and hearing
determination, this final determination as to categorization is subject to appeal as
specified in Rule 7 6(a)
6. Respondents
The following are respondents in Phase I of this OIR Pacific Gas and
Electric Company (PG&E), Southern California Edison Company (SCE), San
Diego Gas and Electric Company (SDG&E), PacifiCorp, CALPECO (Liberty
Utilities) and Bear Valley Electric Service Phase II of this OIR includes the above
named respondents and also includes all Class A, B, C and D water companies
regulated by the Commission
7. Service of OIR
This OIR shall be served by the Commission on all respondents In the
interest of broad notice, this OIR will also be served on the official service lists for
the following proceedings
R 14-08-012 (Order Instituting Rulemaking to Consider Proposed
Amendments to General Order 95),
R 01-10-001 (Order Instituting Rulemaking to Revise Commission
General Order Numbers 95 & 128),
R 08-11-005 (Order Instituting Rulemaking to Revise and Clarify
Commission Regulations Relating to Safety of Electric Utility and
Communications Infrastructure Provider Facilities),
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R 02-11-039 (Rulemaking to Implement the Provisions of Public
Utilities Code Section 7613 Enacted by Chapter 19 of the 2001-2002
Second Extraordinary Legislative Session),
R 10-09-001 (Order Instituting Rulemaking to Implement
Commission Regulations Relating to the Safety of Electric Utility
Substations),
R 07-12-015 (Order Instituting Rulemaking on the Commission's
Own Motion to Revise General Order 103),
This OIR will also be served on all California Publicly Owned
Electric Utility Companies listed in Appendix D,
This OIR will also be served on all Rural Electric Cooperatives listed
in Appendix E,
This OIR will also be served on the Public Owned Utilities
Representatives and Agents listed in Appendix F,
This OIR will also be served on Facilities-Based Communications
Carriers authorized to operate in California listed in Appendix G,
This OIR will also be served on the service list for Resolution No
W-4823 (Order Authorizing Revisions To General Order 103-A
Section 113 C 5, Minimum Standards For Repairs, And
Section IV 1 A Method Of Measuring Service) listed in Appendix H,
and
Respondents Pacific Gas and Electric (PG&E), Southern California Edison
(SCE), San Diego Gas and Electric (SDG&E), PacifiCorp, CALPECO (Liberty
Utilities) and Bear Valley Electric Service are directed to serve a copy of this OIR
on every city, county, or city and county within its service area in California.
Service of this OIR on every city, county or city and county by the Respondents
should be done as soon as feasibly possible, but no later than 30 days after this
OIR is served upon the Respondents by the Commission Within 45 days of
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service of this OIR, Respondents shall file proof of service on every city, county
or city and county with the Commission
Service of this OIR does not confer party status or place a person who has received
such service on the Official Service List for this proceeding
8. Filing and Service of Comments and Other
Documents
Filing and service of comments and other documents in the proceeding are
governed by the rules contained in Article 1 of the Commissions Rules of
Practice and Procedure (See particularly Rules 15 through 110 and 113 )
If you have questions about the Commissions filing and service
procedures, contact the Docket Office (Docket office@cpuc ca g_ov ) or check the
Practitioners' Page on our web site at www CPUC ca gov
9. Addition to Official Service List
Addition to the official service list is governed by Rule 1 9(f) of the
Commissions Rules of Practice and Procedure
Respondents are parties to the proceeding (see Rule 14(d)) and will be
immediately placed on the official service list
Any person will be added to the "Information Only" category of the
official service list upon request, for electronic service of all documents in the
proceeding, and should do so promptly in order to ensure timely service of
comments and other documents and correspondence in the proceeding (See
Rule 1 9(f) ) The request must be sent to the Process Office by e-mail
(processoffice@cpuc ca. ov) or letter (Process Office, California Public Utilities
Commission, 505 Van Ness Avenue, San Francisco, California 94102) Please
include the Docket Number of this rulemaking in the request
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Persons who file responsive comments thereby become parties to the
proceeding (see Rule 14(a)(2)) and will be added to the "Parties" category of the
official service list upon such filing In order to assure service of comments and other
documents and correspondence to advance of obtaining party status, persons should
promptly request addition to the "Information Only" category as described above, they
will be removed from that category upon obtaining party status
10. Subscription Service
Persons may monitor the proceeding by subscribing to receive electronic
copies of documents in this proceeding that are published on the Commission's
website There is no need to be on the official service list in order to use the
subscription service Instructions for enrolling in the subscription service are
available on the Commissions website at http //subscribecpuc cpuc ca gov/
11. Public Advisor
Any person or entity interested in participating in this Rulemaking who is
unfamiliar with the Commissions procedures should contact the Commission s
Public Advisor's Office in San Francisco at (415) 703-2074 or (866) 849-8390 or
e-mail public advisor@cpuc ca gov The TTY number is (866) 836-7825
12. Intervenor Compensation
Any party that expects to claim intervenor compensation for its
participation in this rulemaking must file its notice of intent to claim intervenor
compensation within 30 days of the filing of comments, except that notice may be
filed within 30 days of a prehearing conference in the event that one is held (See
Rule 171(a)(2) )
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13. Ex Parte Communications
This proceeding is subject to Article 8 of the Commission's Rules, which
specifies the standards to be followed for communicating with a decision maker
Pursuant to Rule 8 3(a), ex parte communications are allowed without any
restrictions or reporting requirements unless an appeal of the categorization
pursuant to Rule 7 6 is successful or until the categorization of this proceeding,
or the applicable phase of this proceeding, is changed from quasi-legislative
Therefore, IT IS ORDERED that
1 Pursuant to Rule 6.1 of the Commissions Rules of Practice and Procedure,
this rulemaking is instituted on the Commission's own motion to establish
policies, procedures, and rules pertaining to the physical security for the electric
supply systems of electrical corporations within California consistent with Public
Utilities Code Section 364
2 Pursuant to Rule 61 of the Commissions Rules of Practice and Procedure,
this rulemaking is instituted on the Commission's own motion to establish
standards for disaster and emergency preparedness plans for electrical
corporations and regulated water companies in California consistent with Public
Utilities Code Section 768 6
3 This rulemaking will be conducted in phases Phase I will pertain to the
physical security for the electric supply systems of electrical corporations and
additional phases will pertain to disaster and emergency preparedness plans for
electrical corporations and regulated water companies
4 This rulemaking may consider whether any new rules, standards, or
General Orders or modifications to existing policies should apply to all electrical
supply facilities within the jurisdiction of the Commission, including facilities
owned by publicly owned utilities and rural electric cooperatives
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5 Pacific Gas and Electric Company (PG&E), Southern California Edison
Company (SCE), San Diego Gas and Electric Company (SDG&E), PacifiCorp,
CALPECO (Liberty Utilities), and Bear Valley Electric Service are named as
respondents to both phases of this proceeding All regulated Class A, B, C and D
water companies listed in official Commission records are named respondents in
Phase II of this proceeding
6 This proceeding is preliminarily classified as quasi-legislative, and it is
preliminarily determined that evidentiary hearings will not be necessary
7 No later than 30 days after the Commission adopts this Order Instituting
Rulemakmg, any person may file opening comments addressing whether the
questions set forth above in sections 31 and 3 2 are the appropriate questions to
consider, whether the Commission should consider additional questions, and
whether there are other issues in this proceeding that the Commission should
consider
8 Any person may file comments on the scope, schedule, categorization, or
need for hearing no later than 30 days after the Commission adopts this Order
Instituting Rulemakmg
9 The Executive Director shall cause this Order Instituting Rulemakmg (OIR)
to be served on the following Respondents Pacific Gas and Electric Company
(PG&E), Southern California Edison Company (SCE), San Diego Gas and Electric
Company (SDG&E), PacifiCorp, CALPECO (Liberty Utilities), Bear Valley
Electric Service, and all regulated Class A, B, C and D water companies In the
interest of broad notice, this OIR shall also be served on the official service lists in
Rulemakmg (R ) 14-08-012, R 01-10-001, R 08-11-005, R 02-11-039, R 10-09-001,
R 07-12-015, all Publicly-Owned Electric Companies, rural electric cooperatives
and other Publicly-Owned Utilities' Representatives listed in Appendices D, E,
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R 15-06-009 ALJ/GK1/lt2
and F, on Facilities-Based Communications Carriers authorized to operate in
California listed in Appendix G, and the service list from Resolution No W-4823
listed in Appendix H
10 Respondents Pacific Gas and Electric Company, Southern California
Edison Company, San Diego Gas and Electric Company, PacifiCorp, CALPECO
(Liberty Utilities) and Bear Valley Electric Service are shall serve a copy of this
Order Instituting Rulemakmg (OIR) on every city, county, or city and county
within its service area in California Service of this OIR on every city, county or
city and county by the Respondents shall be done no later than 30 days after this
OIR is served upon the Respondents by the Commission. Within 45 days of
service of this OIR, Respondents shall file proof of service on every city, county
or city and county with the Commission
11 A party that expects to request intervenor compensation for its
participation in this rulemakmg must file its notice of intent to claim intervenor
compensation within 30 days of the filing of comments, except that notice may be
filed within 30 days of a prehearing conference in the event that one is held (see
Rule 171(a)(2) )
12 Ex parte communications in this Rulemaking are governed by Rule 8 3(a) of
the Commission's Rules of Practice and Procedure
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13 The assigned Commissioner or Administrative Law Judge may adjust the
schedule identified herein and refine the scope of this proceeding as needed to
promote the efficient and fair resolution of the rulemakmg
This order is effective today
Dated June 11, 2015, at San Francisco, California
MICHAEL PICKER
President
MICHEL PETER FLORIO
CATHERINE J K SANDOVAL
CARLA J PETERMAN
Commissioners
Commissioner Liane M Randolph, being
necessarily absent, did not participate
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Appendix A
(Senate Bill 699 amending Public Utilities Code Section 364)
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BILL NUMBER SB 699 CHAPTERED
An act to amend Section 364 of the Public Utilities Code, relating to public
utilities
SB 699, Hill Public Utilities electric corporations
Under existing law, the Public Utilities Commission has regulatory
authority over public utilities, including electrical corporations, as defined
Existing law requires the commission to adopt inspection, maintenance, repair,
and replacement standards for the distribution systems of electrical corporations
in order to provide high-quality, safe, and reliable service Existing law requires
the commission to conduct a review to determine whether the standards have
been met and to perform the review after every major outage
This bill would require the commission, in a new proceeding, or new
phase of an existing proceeding, to commence on or before July 1, 2015, to
consider adopting rules to address physical security risks to the distribution
systems of electrical corporations
Under existing law, a violation of the Public Utilities Act or any order,
decision, rule, direction, demand, or requirement of the commission is a crime
Because the provisions of this bill are within the act and require action by
the commission to implement its requirements, a violation of these provisions
would impose a state-mandated local program by expanding the definition of a
crime
The California Constitution requires the state to reimburse local agencies
and school districts for certain costs mandated by the state Statutory provisions
establish procedures for making that reimbursement
This bill would provide that no reimbursement is required by this act for a
specified reason
R 15-06-009 ALJ/GK1/lt2
THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS
SECTION 1.
The Legislature finds and declares all of the following
(a) Physical threats to the electrical distribution system present risks to public
health and safety and could disrupt economic activity in California
(b) Ensuring appropriate actions are taken to protect and secure vulnerable
electrical distribution system assets from physical threats that could disrupt safe
and reliable electric service, or disrupt essential public services, including safe
drinking water supplies, are in the public interest
(c) Proper planning, in coordination with the appropriate federal and state
regulatory and law enforcement authorities, will help prepare for attacks on the
electrical distribution system and thereby help reduce the potential consequences
of such attacks
SEC. 2.
Section 364 of the Public Utilities Code is amended to read
364.
(a) The commission shall adopt inspection, maintenance, repair, and replacement
standards, and shall, in a new proceeding, or new phase of an existing
proceeding, to commence on or before July 1, 2015, consider adopting rules to
address the physical security risks to the distribution systems of electrical
corporations The standards or rules, which shall be prescriptive or performance
based, or both, and may be based on risk management, as appropriate, for each
substantial type of distribution equipment or facility, shall provide for high-
quality, safe, and reliable service
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(b) In setting its standards or rules, the commission shall consider cost, local
geography and weather, applicable codes, potential physical security risks,
national electric industry practices, sound engineering judgment, and experience
The commission shall also adopt standards for operation, reliability, and safety
during periods of emergency and disaster The commission shall require each
electrical corporation to report annually on its compliance with the standards or
rules Except as provided in subdivision (d), that report shall be made available
to the public
(c) The commission shall conduct a review to determine whether the standards
or rules prescribed in this section have been met If the commission finds that the
standards or rules have not been met, the commission may order appropriate
sanctions, including penalties in the form of rate reductions or monetary fines
The review shall be performed after every major outage Any money collected
pursuant to this subdivision shall be used to offset funding for the California
Alternative Rates for Energy Program
(d) The commission may, consistent with other provisions of law, withhold from
the public information generated or obtained pursuant to this section that it
deems would pose a security threat to the public if disclosed
SEC. 3.
No reimbursement is required by this act pursuant to Section 6 of Article XIII B
of the California Constitution because the only costs that may be incurred by a
local agency or school district will be incurred because this act creates a new
crime or infraction, eliminates a crime or infraction, or changes the penalty for a
crime or infraction, within the meaning of Section 17556 of the Government
Code, or changes the definition of a crime within the meaning of Section 6 of
Article XIII B of the California Constitution (End of Appendix A)
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R.15-06-009 ALJ/GK1/jt2
Appendix B
(Regulation of Physical Security for the Electric Distribution System, February 2015)
ALJ/GK1/jt2 '
1
Regulation of Physical Security for the
Electric Distribution System
February 2015
BEN BRINKMAN
SAFETY AND ENFORCEMENT
DIVISION, ELECTRIC SAFETY AND
RELIABILITY BRANCH
CONNIE CHEN
ENERGY DIVISION,
INFRASTRUCTURE PLANNING AND
PERMITTING BRANCH
ARTHUR O'DONNELL
ENERGY DIVISION,
INFRASTRUCTURE PLANNING AND
PERMITTING BRANCH
CHRIS PARKES
SAFETY AND ENFORCEMENT
DIVISION, RISK ASSESSMENT
SECTION
, gviu�cp
5
Edmund G Brown Jr . Governor
ALJ/GK1/jt2
The views presented in this paper are those of staff and do not necessarily represent the views of the five member
California Public Utilities Commission This paper is intended to initiate a dialog on the topics discussed and any
recommendations are preliminary Staff may revise this paper based on further discussion and comments received
11
ALJ/GK1/jt2 '
EXECUTIVE SUMMARY AND MAJOR TAKEAWAYS
Executive Summary
On April 16, 2013, Pacific Gas and Electric Company's (PG&E's) Metcalf Substation sustained
millions of dollars in damages from a gunshot attack that destroyed several transformer oil tanks
at the facility Fortunately, no customers lost power due to the event, but a similar attack under
different circumstances might have been catastrophic
As a result of this attack, public concern regarding security of the electric grid, which is typically
reserved for cyber protection of electric facilities, expanded to include concern over physical
security measures for the electric grid The Federal Energy Regulatory Commission (FERC)
tasked the North American Electric Reliability Corporation (NERC) with developing a standard
for physical security at the most critical bulk-power level substations While these new federal
standards are limited to a select group of transmission level substations, the California Public
Utilities Commission(CPUC or the Commission) is examining grid security at all levels of the
electric supply system, including the distribution level, and is re-evaluating its existing policies
and oversight activities for electric system security
CPUC staff held a two day workshop on substation physical security in June, 2014 CPUC staff
assembled a panel of electric grid security experts to discuss major issues in physical security
The first day consisted of public workshops, during which PG&E elaborated on its security
improvements since the Metcalf substation attack, and the expert panel discussed current security
threats and best practices in physical security During the second day, representatives from the
major California utilities presented their specific physical security measures to CPUC staff in a
closed door meeting, followed by a roundtable discussion of existing and pending state and
federal security related legislation and regulations
On September 25, 2014, California's governor signed into law California Senate Bill 699 (See
Appendix A) which requires the Commission to develop rules for physical security of the electric
distribution system
ut
ALJ/GK1/jt2
The purpose of this whitepaper is to discuss the current and potential regulatory framework
around electric distribution system physical security, to present the process involved in
evaluating potential security measures, to identify questions the Commission should address in
developing rules for physical security, and to recommend a possible methodology for utility
electric distribution system physical security planning
Major Takeaways
1 Security of the electric distribution system is an important concern for protection of life
and to provide and maintain a safe and reliable power delivery system Physical security
measures represent important considerations in an asset protection scheme that includes
cybersecurrty and information security It is impossible to completely separate physical
security from cyber and information security
2 Although physical attacks on electric facilities occur with some regularity, none to date
have caused major, widespread outages affecting the stability of the grid However,
given recent events and analysis, and the potential for malevolent actors to disrupt the
electrical system, physical security for the electric grid is a significant concern
3 In 2014, NERC developed a new standard for electric grid physical security, however
NERC CIPI security regulations are limited to bulk-power assets2 and therefore do not
apply to the lower voltage electric distribution system
4 Because of the limits of federal regulations, a critical role exists for state government,
including the Commission, in enforcing physical security at the distribution level In fact,
existing Commission rules already establish some requirements regarding distribution
system physical security
5 New state legislation mandates Commission action to develop rules for physical security
for the distribution system in a new or existing proceeding
Critical Infrastructure Protection
2 Bulk power here refers to those transmission and generation assets covered by NERC standards The definition of
the"bulk-power"system has been evolving through a stakeholder process but typically generally refers to assets
operating at a voltage over 100kV
http//www mondaq com/unitedstates/x/215222/Oil+Gas+Electricity/FERC+Approves+Revised+Bulk+Electric+Sys
tem+Deft nition+And+Reserves+Authority+To+Determine+Local+Distribution+Face Itties
1V
ALJ/GK1/jt2
6 The recent state legislation addresses only the "distribution system " However, the
processes and elements of physical security planning are applicable to all levels of the
electric supply grid
7 Security planning should consider multiple factors Public Utilities Code Section 364, as
amended by Senate Bill 699, enumerates cost, local geography and weather, applicable
codes, potential physical security risks, national electric industry practices, sound
engineering judgment, and experience Other impacts including environmental impact
should also be considered
8 Although the specific methodologies and threats differ, varied industries, including
electric utilities, choose from a similar menu of options for physical security mitigation
Physical security includes practices to deter, detect, and respond to unauthorized access
or attacks This includes actions such as constructing walls, using intrusion detection and
lighting, and employing security forces Utilities augment these purely physical efforts
with cyber and information security activities and security policies and practices
9 Electric system physical security can be costly, therefore, given the vast array of
distribution equipment, design, and other external considerations, it is virtually
impossible for regulators to establish a"one-size-fits-all" approach that would work for
all utilities A performance based approach with reliable metrics lends itself well to a
system with varied equipment Detailed prescriptive measures will likely not be feasible
in many instances, however general guidelines and requirements may be appropriate In
addition, the utilities should consider accepted good practices as developed by industry
organizations
10 A sound planning methodology would use a risk based approach Under a risk based
approach the Commission would require utility planners to identify and assess risks and
vulnerabilities, develop mitigation plans from various alternatives, and assemble tests and
metrics for evaluating their plans The utility should consider alternatives and justify the
alternatives chosen with respect to efficacy, cost, and other significant considerations
3 Senate Bill 699, amending Public Utilities Code Section 364
v
ALJ/GK1/jt2
11 The Commission should consider protection of critical security information as part of its
regulatory standard development process Because Senate Bill 699 specifies that the
Commission may withhold from the public certain information whose release would pose
a security threat, it would be appropriate for the rulemakmg to consider the types of
information that warrant confidential treatment under the statute
Recommendations
1 The CPUC should open a rulemakmg to evaluate and update existing requirements
regarding physical security of the electric system, in a manner consistent with Senate Bill
699
2 The CPUC should address the following during the rulemakmg
o What does the "distribution" system, as that term is used in Senate Bill 699,
consist of,
o Is there anyjurisdictional overlap (FERC, NERC, CAISO, etc)
o Should the CPUC rules include requirements for bulk power level facilities
o Which sorts of rules are best—Prescriptive� Performance baseP A
combination�
o How should risk be consadereP
o Should the Commission base its physical security rules on existing rules or
standards, such as NERC CIP 14�
o What constitutes "physical security" measures that should be adopted under
Senate Ball 699
o At a high level, what elements are important an a physical security program
o How should the Commission balance cost with security
o How should the Commission balance environmental issues with securary�
o How should the Commission determine accepted best practices an physical
securaty�
o In enforcing the regulations on physical security, how should the Commission
protect sensitive information? Are current confidentiality rules and practices
sufficient
vi
ALJ/GK1/jt2
o What metrics, tests, or drills can be employed to determine effectiveness of a
security plan
o What prescriptive guidelines should be included as part of the regulations?
o Should the rules apply to publicly owned utilities?
o How should the rules be enforced? What should be the timeline for the first
security plan submissions and updates? What should be the implementation
timeline
o How often should the system be re-analyzed?
o What sorts of events should undergo root cause analysis
o Should the Commission require the utilities to use independent security experts
to prepare, vet or test the utility security plans?
o Should the Commission contract its own independent security expert to assist in
development of rules?
3 Commission rules should require a risk based approach to physical security planning
Under the recommended risk based approach, the utility would be required to identify
and assess risks to its facilities and develop a plan to mitigate those risks The utility
would also be required to develop clear metrics to evaluate the success of its plan The
utility would present this plan to the Commission and submit updates to the plan as
necessary The utility would need to report annually on its compliance with the adopted
rules, as required by Senate Bill 699
4 The utility should be required to consider various alternatives and justify that the choices
chosen are optimal with respect to mitigating risks at an appropriate cost level The
utilities should also consider additional factors, including those identified in Section 364
and also other factors, such as environmental impacts, when designing their security
plans
5 A hybrid approach, including the performance based rules referenced above along with
some high level prescriptive guidelines, may be the optimal approach
6 The utilities should justify their security planning choices based on industry best
practices The utilities should refer to existing standards such as IEEE standards on
vii
ALJ/GK 1/jt2
Substation Physical Security4 or other recognized industry standards in justifying their
plans The utilities should also be required to develop and employ metrics and regularly
evaluate the results of those metrics as justification for continuing or changing their
plans
7 Drills and testing of the security plans should be included in every utility security plan
The drills should include surprise inspections and simulated real life events that stress the
security system Periodic testing of alarms, access, and monitoring equipment is also
critical Where appropriate, the utility should perform root-cause analysis of any failures
detected in the drills
8 The Commission may consider whether to require the utilities to vet their plans through
independent third party experts before submission, and whether the utilities should use
third parties in testing their plans Additionally, the Commission should determine if it
wishes to contract its own third party expert for assistance in development of rules
9 Protection of sensitive information is a critical concern The Commission should
consider the appropriate confidentiality measures for sensitive security information It
may be appropriate for Commission staff to take appropriate training on protecting
critical infrastructure information
a IEEE Standards Association 2014 See http//standards ieee org/findstds/standard/1402-2000 html
vill
ALXGK1/it2
Contents
EXECUTIVE SUMMARY AND MAJOR TAKEAWAYS ui
Executive Summary ui
Major Takeaways iv
Recommendations vi
1 0 Introduction 1
20 Definition of Physical Security 2
2 1 Physical Security, Cybersecurity, and Information Security 4
30 Significant Incidents at Electrical Facilities 4
40 Federal and State Initiatives, Laws, and Regulatory Responses 7
4 1 Critical Infrastructure Protection Standards— CIPs 9
4 2 Other Physical Security Standards 12
4 3 Existing CPUC Regulation and Oversight Activities 12
4 3 1 Metcalf Attack and Metcalf Burglary 13
4 4 Physical Security Activities in other States and Power Agencies 14
5 0 Examples of Physical Security from Other Industries 15
5 1 Physical Security in the Nuclear Industry 15
5 2 Physical Security in the Chemical Industry 16
5 3 Physical Security for the Financial Sector 16
5 4 Military Physical Security 17
6 0 Risk Based Physical Security for the Electric Grid 17
6 1 Risk Management Process 17
6 2 Risk Identification and Assessment(Evaluate Risks, Threats, and Vulnerabilities) 18
6 3 Risk Mitigation(Control Risks) 20
6 3 1 Physical Mitigation 20
6 3 2 Policies and Procedures Related to Physical Security 25
6 3 3 Other Considerations for Risk Mitigation Planning 25
6 4 Metrics (Review Controls) 29
6 4 1 Prescriptive versus Performance Based Regulations 29
ix
ALJ/GK1/jt2
6 4 2 Control Metrics for Utility Distribution Systems 30
7 0 Proposed Next Steps for the Commission 32
7 1 Development of Rules Required by Senate Bill 699 32
7 1 1 Potential Model for Rules for Physical Security 32
7 1 2 Protection of Sensitive Information 37
8 0 Conclusion 38
Appendix A 40
Appendix B 42
x
ALJ/GK1/it2 '
1.0. Introduction
Recent events, in particular the April 2013 attack on the Metcalf Substation, and subsequent new
standards by the North American Electric Reliability Corporation (NERC, formerly the North
American Electric Reliability Council) have focused attention on the physical security of the
electric grid In California, new legislation at the state level requires the California Public Utilities
Commission (CPUC) to develop rules to address physical security risks at the electric distribution
level
This whitepaper discusses the relevant issues in physical security for the electric distribution
system, with a particular focus on advising policymakers on implementation scenarios for the new
requirements codified in Section 364 of the Public Utilities Code, as amended by Senate Bill 699 5
Section 364 of the Public Utilities Code requires, in part,
The commission shall, in a new proceeding, or new phase of an existing proceeding, to
commence on or before July 1, 2015, consider adopting rules to address the physical
security risks to the distribution systems of electrical corporations The standards or rules,
which shall be prescriptive or performance based, or both, and may be based on risk
management, as appropriate,for each substantial type of distribution equipment or facility,
shall provide for high-quality, safe, and reliable service
The electric grid consists of generation, transmission, and distribution facilities The transmission
and distribution systems consist of overhead and underground lines, and substations which convert
voltage levels and switch power Generators typically deliver power to the bulk-power high
voltage transmission system, which in turn delivers that power to the lower voltage distribution
system for delivery to end users 6 The bulk-power transmission system is generally defined as
those lines and substations operating above 100 kV Lower voltage level transmission lines and
substations, often referred to as sub-transmission, operate from around 25 kV to 100 kV
Substations then convert these transmission and sub-transmission level voltages to lower
distribution level voltages (typically 4 kV, 12 kV, or 15 kV) for delivery to end users
5 California State Senate Bill 699 See
http Hlegmfo legislature ca gov/faces/billNavChent xhtml9bill_id=201320140SB699
6 Also, increasing numbers of distributed energy resources and energy storage facilities interconnect at the distribution
level
1
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Electric Delivery System?
Since the 2013 Metcalf Substation attack, and even before that attack, a great deal of public
attention has focused on security at the bulk-power level This whitepaper does not focus strictly
on those assets, but discusses physical security measures in general for the entire electric grid
Most security measures pertinent to distribution substations also apply to transmission level
substations, and elements of physical security pertinent to other distribution infrastructure also
pertain to similar overhead and underground transmission facilities The differences lie in the
impact assessments and the particular structures involved in the physical security planning (e g ,
poles verses towers)
2.0. Definition of Physical Security
Physical security, as opposed to cybersecurity, refers to physical deterrence, monitoring, and
mitigation activities A restrictive definition of physical security includes only those elements and
strategies directly involved in physical protection- perimeter walls and fencing, lighting, cameras
and security patrols This paper adopts a somewhat more expansive definition, which also includes
certain elements of policies, procedures and training related to the physical protection of grid
facilities (e g , background screening of guards) as well as some elements of cybersecurity
necessary for the functioning of physical security safeguards (e g , alarm interpretation software)
This paper does not discuss in detail the security for critical bulk power transmission facilities
covered under NERC regulations, but rather security for the entire electric delivery system
including transmission and distribution facilities, including substations The processes discussed
here should apply to all types of utility facilities
'Adapted by Congressional Research Service from U S-Canada Power System Outage Task Force, Final Report on
the August 14,2003 Blackout in the United States and Canada Causes and Recommendations, April 2004, Figure 2 1
2
ALJ/GK1/lt2 '
The physical security of the bulk-power grid has long been a matter of concern for policy makers,
and attention to these assets increased significantly following the 2013 Metcalf Substation attack
In June 2014 the Congressional Research Service prepared a paper entitled"Physical Security of
the US Power Grid High Voltage Transformer Substations " The paper focused on the threat to
bulk-power level substations, and in particular the risks and vulnerabilities associated with
transformers in these substations
Even prior to the Metcalf attack, federal agencies conducted vulnerability studies of the electric
grid In 2011 NERC conducted Grid-Ex I In this exercise, NERC determined that although the
utilities "took appropriate steps to protect the grid," NERC should facilitate the development of
updated physical security standards 8 In 2013, following the Metcalf attack, NERC conducted
Grid-Ex 1I, in which it determined that
While the electricity industry has experienced occasional acts of sabotage or vandalism, a
well-coordinated physical attack also presents particular challenges for how the industry
restores power The extreme challenges posed by the Severe Event scenario provided an
opportunity for participants to discuss how the electricity industry's mutual aid
arrangements and inventories of critical spare equipment may need to be enhanced 9
In 2013 FERC conducted its"Electrically Significant Locations" study in which it modeled power
flow in the transmission system and identified 30 critical substations across the United States
Although disputed by some experts, the study also determined that disabling only 9 of these
substations could potentially cause an extended national blackout 10
Although high voltage transmission level transformers are certainly a critical point of concern, they
are not the only vulnerability in the electric grid As such, on June 17 and 18, 2014, the CPUC
held public and closed workshops on substation and overall grid physical security, which included
participation by major utilities in the state as well as industry experts from NERC, Lawrence
Livermore Laboratory, and the Department of Homeland Security (DHS) As part of planning this
8 North American Electric Reliability Corporation(NERC), 2011 NERC Grid Security Exercise After Action Report,
March 2012,p n
9 North American Electric Reliability Corporation(NERC), Grid Security Exercise(GridEx II) After-Action Report,
March 2014,p 5
10 Rebecca Smith,"U S Risks National Blackout from Small-Scale Attack on Substations," Wall Street Journal,
March]3, 2014
3
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event, Commission staff also spoke with personnel from the Federal Bureau of Investigation (FBI)
Much of the information in this paper was derived from information presented publicly by utility,
industry and security experts at the event
2.1. Physical Security, Cybersecurity, and Information Security
It is impossible to completely separate effective physical security measures from cyber security and
information security measures 11
A significant element of physical security involves alarms and
visual monitoring (cameras) For these to be effective, information must be transmitted to control
or security centers Therefore, communications systems must remain intact and fully operational,
making cyber protection a critical concern Additionally, physical security measures can be
rendered ineffective if critical information about those measures is made public
3.0. Significant Incidents at Electrical Facilities
The major risks associated with a physical attack against electricity grid facilities are incidents that
cause substantial enough damage, and result in widespread outages that last for days or weeks as
critical equipment is repaired or replaced While there have been many examples of extreme
weather events—including heavy winds, tornadoes and hurricanes, ice storms, and fires beneath
high voltage transmission lines -- that have resulted in such disruptions, to date in the United
States there have been no such extended outages that stem from a planned attack on transmission or
substation facilities 12
Even the damage to electric transformers at PG&E's Metcalf Substation did not cause outages,
despite a cost of repairs estimated at $15 4 million Some 100 bullets fired at the substation caused
damage to 17 transformers and six circuit breakers, with the major damage being to transformer
radiators that leaked 52,000 gallons of cooling oil However, the incident did not result in any
disruption of service 13
Still, vandalism and other physical attacks on utility facilities represent a substantial number of
incidents reported to a federal agency During 2013 and 2014 (reported through October 1), the
11 CPUC Substation Security workshops,June 2014
12 Parformak, Paul W, Physical Security of the U S Power Grid High-Voltage Transformer Substations,
Congressional Research Service, June 17, 2014, pg 2
13 SED Presentation to CPUC on PG&E Metcalf Incident and Substation Security, February 27,2014
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U S Department of Energy's Office of Electricity Delivery and Energy Reliability received 352
incident reports, weather related events made up 37 percent while combined physical
attacks/vandalism/sabotage were also declared in 37 percent Cyber-attacks were responsible for
just 3 of the reports, according to DOE Fuel shortages, unintentional islanding and various
electrical disturbances comprise the rest
System Incidents Reported to DOE
2013-2014
200
180
160
140
120
100
80
60
40 ■2013
20
o physic ■2014
physic al vanda
Island load sabots weath
cyber fuel al attack lism/t other total
attack /vand ge heft
trig drop er
alism
E0141
2 8 11 8 24 31 4 23 62 8 181
16 13 10 19 28 1 1 70 12 171
Source DOE Submissions of all Electric Emergency Incident and Disturbance Reports(OE-417),
http//www oe ned doe gov/oe417 aspx
Despite many incident reports that cited Physical Attack Nandalism/Suspicious Activity or
Sabotage, only two resulted in documented power outages or loss of load for more than 2 hours 14
In contrast, weather incidents severe enough to be reported invariably affected hundreds to
hundreds of thousands of utility customers, sometimes for extended periods
Purposeful attacks on electric utility facilities may be reported to DOE as "sabotage" or vandalism
(often including theft of copper wire), but they are rarely revealed in the media, although a few
incidents have become public In October 2005, a rifle attack was reported at a Progress Energy
substation in Florida, which resulted in a small explosion, a transformer oil leak, and local power
14 DOE Office of Electricity Delivery and Energy Reliability,web site report November 25,2014
http//energy gov/oe/services/energy-assurance/monitoring-reporting-analysis/electric-disturbance-events-oe-417
5
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outage 15 More recently, in June 2014, a device described as a"homemade bomb" by authorities
ignited a small fire at a Nogales, AZ, substation The fire left burn marks on a 50,000-gallon diesel
storage tank at the Valencia substation without interrupting power to the area The incident has
been termed "sabotage" by DOE
These incidents remain unsolved, but there has been one high-profile case in which federal
investigators have identified and arrested a "lone wolf'perpetrator who caused several millions of
dollars in damage to utility infrastructure
In October 2013, the United States Department of Justice charged an Arkansas man with sabotage,
a terrorist attack against a railroad and destruction of an energy facility, stemming from incidents
that occurred over the course of several months in Lonoke County, AR In one attack on August
21, 2013, the man allegedly removed over 100 bolts securing a 100 foot 500 kV transmission tower
leaving only five in place, and proceeded to sever a shackle on a support wire Subsequently, the
tower fell onto nearby railroad tracks and was struck by a train, causing a brief power outage
In a separate incident, on September 29, 2013, the same person allegedly set fire to an Entergy high
voltage switching station, leaving behind a message "You should have expected U S "16 Finally,
on October 6, 2013, First Electric Cooperative experienced a power outage affecting 9,200
customers Utility and law enforcement investigations indicated that two power poles had been cut
and pulled down by a stolen tractor 17
A joint investigation by the Federal Bureau of Investigation, the Joint Terrorism Task Force and a
dozen other federal, state and local agencies quickly led to an arrest less than one week following
the final incident The man, Jason Woodring of Jacksonville, AR, was indicted on 8 federal counts,
including a terrorist attack, destruction of an energy facility, and illegal possession of weapons and
drugs As of January 2015, he awaits trial
In most cases, it may be difficult to ascertain when an attack on utility facilities is a planned event
meant to cause service disruptions, or a crime of opportunity by vandals
15 Parformak, op cit, pg 7
16"Power Grid is Attacked in Arkansas,"New York Times,October 8,2013
17 U S Department of Justice, U S Attorney for the Eastern District of Arkansas, news release,October 12,2013
6
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On the eve of the new millennium, in 1999, when utilities around the globe prepared for a potential
disruption to their computer-driven operations due to the infamous Y2K programming glitch, the
Western U S grid saw only one actual system outage that resulted from a fallen transmission tower
in Oregon According to the California Independent System Operator (CAISO), the tower was
adjacent to an Indian reservation Someone reportedly hopped a fence, cut a guide wire and
removed bolts, allowing a strong wind to topple the tower 18
Even though the actual impacts of reported physical attacks on the electric grid have been minimal,
there is no reason to downplay the potential threat that a well-planned and coordinated attack on
the grid might pose A previously confidential 2013 analysis from the Federal Energy Regulatory
Commission (FERC), which was publicly revealed by a Wall Street Journal article, warned that a
coordinated attack on as few as nine electric transmission substations in various combinations
around the country could potentially cause cascading outages in each of the nation's three
synchronized power networks Although the analysis itself was a cause for concern, it appeared
that the public release of the information brought far greater criticism in Washington, D C , with
FERC officials and lawmakers condemning the newspaper for undermining grid security—
although the news article did not identify what facilities were deemed at risk in the "worst case"
scenario 19
However, the combination of the Journal article and the PG&E Metcalf incident has heightened the
issue of physical security to a place more equal to the concerns expressed about cybersecurity
4.0. Federal and State Initiatives, Laws, and Regulatory Responses
Efforts by the U S Government to define and address the security of the electricity system have
waxed and waned over the past two decades, with concerns about physical security most often
taking a back seat to perceived cybersecurity vulnerabilities In 1996, for example, President
Clinton's Administration established the President's Commission on Critical Infrastructure
Protection to make recommendations on policies related to the vulnerabilities and threats to the
18 O'Donnell, Arthur,"Soul of the Grid"2004,pg 124
19 E&E News, "FERC's confidential threat analysis triggers political reaction," March 14, 2014
7
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nation's critical infrastructure 20 The report, dated October 1997, found "no immediate crisis
threatening the nation's infrastructures" but did recommend immediate actions on the cybersecurrty
front 21 The recommendations eventually led to a Presidential Decision Directive No 63 (PDD-63)
in 1998, which set a goal of securing the nation's critical infrastructure from both physical and
cyber-attacks by the year 2003
The effort was soon superseded in the post-9-11 period, with the establishment of the Office of
Homeland Security (later made a Cabinet-level Department) and subsequent passage of both the
Critical Infrastructures Protection Act of 200122 and the Homeland Security Act of 2002 23 These
laws provided a set of policy goals and a statutory definition of critical infrastructure
It is the policy of the United States 1) that any physical or virtual disruption of the
operation of the critical infrastructures of the United States be rare, brief, geographically
limited in effect, manageable, and minimally detrimental to the economy, human and
government services, and national security of the United States 24
[T]he term "critical infrastructure" means systems and assets, whether physical or virtual,
so vital to the United States that the incapacity or destruction of such systems and assets
would have a debilitating impact on security, national economic security, national public
health or safety, or any combination of those matters 25
In the intervening years, there have been many refinements to the structure of DHS and the various
councils and committees established to advise it and the President These developments tended to
shift the emphasis of national policy to concentrate on cybersecurrty of the grid, while emphasizing
physical security of other critical infrastructures 26 In the wake of Hurricane Sandy's devastating
impacts on Northeastern states, the term "resiliency" has been added as a goal of critical
infrastructure policies embodied in the most recent changes to the National Infrastructure
20 Executive Order 13010 Critical Infrastructure Protection, Federal Register Vol 61,No 138,July 17, 1996
21 Critical Foundations Protecting America's Infrastructures, President's Commission on Critical Infrastructure
Protection, October 1997
22 42 US Code 5195C
23 Public Law 107-296, Sec 214
24 42 US Code 5195C Sec (c)(1)
25 Sec (e)
26 Moteff, John D, Critical Infrastructures Background, Policy and Implementation,Congressional Research Service,
February 21, 2014,provides a detailed review of these developments from 1996 to the present
8
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Protection Plan (NIPP) 27 Resiliency considerations are an important element of substation security
planning and risk assessment NIPP, overseen by DHS' Office of Infrastructure Protection, was
updated as a result of Presidential Policy Directive-21 (PPD-21) in February 2013 According to
DHS director of strategy and policy Bob Kolasky, "[G]rowing interdependencies across
infrastructure systems, particularly reliance on information and communications technologies, have
produced new vulnerabilities to physical and cyber threats The new plan NIPP 2013, guides
efforts across the critical infrastructure community to enhance security and resilience in
conjunction with national preparedness policy "28
This emphasis on cybersecurity is largely mirrored by the plethora of federal legislation introduced,
considered and occasionally chaptered into law, while physical security has received far less
legislative attention 29
4.1. Critical Infrastructure Protection Standards — CIPs
In the national regulatory arena, the interplay between the FERC and NERC has largely provided
the platform for both physical security and cybersecurity efforts in the electric utility industry
FERC is a federal agency, successor to the Federal Power Administration, which has primary
regulatory authority over interstate electric and natural gas transmission, hydroelectricity, and
wholesale power markets NERC, a not-for-profit, non-governmental body charged with organizing
the voluntary reliability efforts of electric utilities in nine regions across the U S , was established
as a direct result of the massive 1965 New York blackout The Energy Policy (EP) Act of 2005
created a new hybrid approach to system reliability with designation of an Electric Reliability
Organization (ERO) to establish mandatory standards governing operations and information
pertaining to the electric utility industry In 2007, FERC designated NERC as the national ERO
responsible for writing standards, while FERC retained its authority to review and approve those
standards
27 The National Infrastructure Protection Plan is a Department of Homeland Security document which outlines how
government and the private sector can partner to develop protocols to protect critical infrastructure Resiliency refers
to the ability of the electric grid,or any system,to prepare for and adapt to serious stressors such as physical attack or
severe weather events
28 Kolasky Interview with Eric Holdeman in Emergency Management magazine, March 21,2014 See
http//www emergencymgmt com/safety/Sharpening-the-Focus-on-Critical-Infrastructure html
29 Fischer, Eric, Federal Laws Relating to Cybersecurity, Overview and Discussion of Proposed Revisions,
Congressional Research Service,June 13, 2013
9
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Even before EP Act 2005, both entities had undertaken approaches to regulating critical
infrastructure Immediately after 9-11, FERC began promulgating rules on Critical Energy
Infrastructure Information (CEII) that severely limited, then refined, the ability of the public and
market participants to access materials like maps and documents that could provide sensitive
information about grid vulnerabilities 30
NERC's efforts to create new, largely voluntary, standards for the power system took the form of
various Critical Infrastructure Protection (CIP) standards Beginning in 2005,NERC members
worked on, and then forwarded for FERC approval, nine initial CIPs, which have become
mandatory and subject to NERC enforcement 31
• CIP-001: Covers sabotage reporting,
• CIP-002: Requires the identification and documentation of the Critical Cyber Assets
associated with the Critical Assets that support the reliable operation of the Bulk Electric
System,
• CIP-003: Requires that responsible entities have minimum security management controls
in place to protect Critical Cyber Assets,
• CIP-004: Requires that personnel with authorized cyber or unescorted physical access to
Critical Cyber Assets, including contractors and service vendors, have an appropriate level
of personnel risk assessment, training, and security awareness,
• CIP-005: Requires the identification and protection of the Electronic Security Perimeters
inside which all Critical Cyber Assets reside, as well as all access points on the perimeter,
• CIP-006: Addresses implementation of a physical security program for the protection of
Critical Cyber Assets,
• CIP-007: Requires responsible entities to define methods, processes, and procedures for
securing those systems determined to be Critical Cyber Assets, as well as the other (non-
critical) Cyber Assets within the Electronic Security Perimeters,
• CIP-008: Ensures the identification, classification, response, and reporting of cybersecurity
incidents related to Critical Cyber Assets, and
30 See FERC's web site for a listing of major CEII regulations, http//www ferc gov/legal/maj-ord-reg/land-docs/cen-
rule asp
31 NERC CIPs do not apply to nuclear energy facilities, which are under jurisdiction of the Nuclear Regulatory
Commission
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• CIP-009: Ensures that recovery plans are put in place for Critical Cyber Assets and that
these plans follow established business continuity and disaster recovery techniques and
practices
CIP standards undergo regular modification On November 22, 2013 FERC approved CIP Version
5 which includes significant changes and additions to the existing collection of standards 32 The
changes are scheduled to become enforceable in 2016
As of early January 2015, CIP-010, Configuration Change Management and Vulnerability
Assessment and CIP-011, Information Protection, as well as CIP-014, Physical Security, are
standards subject to future enforcement 33
Until the recent adoption by FERC of CIP-014, which is specific to critical facilities in the bulk
power system, including substations, but not electric generators,31 CIP-004 and CIP-006 had the
most impact on physical aspects of security FERC's initial directive to NERC to formulate these
physical security standards indicated that a major component of the rules would be for owners and
operators of the grid to perform risk assessment of their system and identify facilities that, if
rendered inoperable or damaged, could have a critical impact on the operation of the interconnected
grid through instability, uncontrolled separation, or cascading failures
FERC recognized that"critical" facilities would be a relatively small subset of all facilities that
comprise the electric grid ,[oq the many substations on the bulk power system, our preliminary
view is that most of these would not be `critical' as the term is used in this order We do not expect
that every owner and operator of the bulk power system will have critical facilities under the
reliability standard »35
The standard requires that owner/operators of the grid"develop and implement a security plan to
protect against attacks on these facilities "36
32 FERC Order No 791 Final Rule http//www ferc gov/whats-new/comm-meet/2013/112113/E-2 pdf
33 NERC Standards Subject to Future Enforcement
http//www nerc com/pa/Stand/Pages/StandardsSubJecttoFutureEnforcement aspx9Jurisdiction=United States
34 RM 14-15-000,approved with modification November 20,2014
35 RD 14-6-000, March 7, 2014, 146 FERC¶61,1666 at P 11
36 FERC news release July 17,2014
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4.2. Other Physical Security Standards
Outside of the national regulatory arena, the electric power industry is looking to develop physical
security standards for substations, regardless of whether they are part of the bulk power system or
local distribution networks not under FERC jurisdiction
The Institute of Electrical and Electronics Engineers (IEEE), a professional association founded in
1963, is responsible for developing many standards for equipment and practices used by the
electric utility industry, including the widely recognized IEEE 1547 standard for safety of all
devices that are interconnected to the grid
As of January 2015, IEEE members are developing P 1402, a Standard for Physical Security of
Electric Power Substations The standard would "define sound engineering practices for substation
physical protection that could be applied to substations that are unmanned, and thus susceptible
to unauthorized access, theft and vandalism"
The prospective standard is mostly concerned with issues of access, monitoring and delay/deter
features to mitigate vulnerability at such facilities P1402 "does not establish requirements based
on voltage levels, size or any depiction of criticality of the substation" but rather leaves it up to the
facility owners to determine applicability to their assets
4.2.1. Other Industry Standards
Several existing industry standards not specifically related to physical security are nonetheless
relevant These include National Fire Protection Association(NFPA) and National Electric Safety
Code (NESC) standards, as well as International Organization for Standardization (ISO) standards
such as ISO 55000 (Asset Management Standard), IS031000 (Risk Management Standard), and
ISO 9001 (Quality Management Standard)
4.3. Existing CPUC Regulation and Oversight Activities
Commission policies and regulations have long included provisions related to electric grid physical
security Commission staff regularly inspects and investigates existing security measures at
electrical facilities During inspections of power plants, underground and overhead facilities and
12
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substations under General Orders 174, 165, 167, 128 and,95,37 Commission staff verifies the
condition and operation of existing physical security protections such as substation fences and
lighting, padmount locks, vault covers, and electric generating station security plans
The Commission evaluates security measures as part of electric utility rate cases CPUC policies
now require the utilities to discuss both safety and risk assessment in every rate case Commission
staff annually review electric utility emergency plans, and regularly monitor utility emergency
exercises as required by General Order 166 38 In addition, Commission staff investigates incidents
related to security at electrical facilities, including both the 2013 Metcalf gunshot attack and the
2014 Metcalf security breach and burglary
4.3.1. Metcalf Attack and Metcalf Burglary
On April 16, 2013, a gunshot attack damaged several high voltage transformers and other
equipment at Pacific Gas and Electric's Metcalf Transmission Substation south of San Jose No
customers lost power and no injuries were reported, but the cost of repairs approached $15 4
million, and the attack rendered the substation inoperable for approximately one month Following
this attack, PG&E initiated several changes to its security protocol at this substation
Despite these changes, between the hours of 22 10 on August 26, 2014, and 02 41 on August 27,
2014, burglars cut through the fence at the Metcalf Substation and removed tools and equipment
valued at $38,651 39
Law enforcement personnel40investigated both incidents with a goal of identifying and
apprehending the perpetrators At the same time, staff from the Commission's Safety and
Enforcement Division (SED) investigated the incidents to evaluate PG&E's security measures and
compliance with Commission regulations 41
Following the 2014 Metcalf burglary, SED directed PG&E to conduct a root cause analysis (RCA)_
into the event Although the full RCA report is confidential, PG&E prepared a non-confidential
37 General Order 95,"Rules for Overhead Electric Lines", General Order 128,"Rules for Construction of Underground
Electric Supply and Communication Systems",General Order 165,"Inspection Requirements for Electric Distribution
and Transmission Facilities", General Order 174,"Rules for Electric Utility Substations", General Order 167,
"Enforcement of Maintenance and Operation Standards for Electric Generating Facilities"
38 General Order 166,"Standards for Operation, Reliability,and Safety During Emergencies and Disasters"
39 PG&E Metcalf Root Cause Analysis Summary report November 21,2014,p2
40 Including local police for both incidents and the FBI for the April 2013 gunshot attack
41 SED's investigation of the August 26-27,2014 incident is on-going
13
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summary document showing its analysis of the causes and major action items it is undertaking in
response to both the 2013 attack and the 2014 break-in (See Appendix B)
4.4 Physical Security Activities in other States and Power Agencies
Our research indicates California leads the way in efforts to improve electric grid physical security
However, some other states and power agencies have undertaken noteworthy efforts in this area
Arizona has a history of both grid security events and utility action in response to these events In
2007, security working at a checkpoint stopped a worker carrying a pipe packed with firework
explosives In February of 2014, target shooters in the vicinity of a Nogales substation were
confronted by plant security and law enforcement In June of the same year, saboteurs detonated a
makeshift explosive device near spare oil tanks at a substation in the same general area Law
enforcement investigated all of these incidents In March 2014, in the wake of the Metcalf attack,
the Arizona Corporation Commission sent a letter to state utility owners asking about planned
improvements to mitigate physical security threats in their facilities 42
Arizona utility activities in the security area predate these events In 2000, the FBI established an
advisory program on substation grid physical security for Arizona utilities Under the "infragard"
program, the federal government shares security information with electric corporations in the state
Pennsylvania Utility Code 52 Chapter 101 requires all jurisdictional utilities to prepare physical and
cyber security plans as part of their emergency preparation, and to self-certify that those plans meet
state requirements 43
The Bonneville Power Administration, a federal power agency operating in the Pacific Northwest,
has conducted hundreds of security and risk assessments since 2001, and to 2014 proposed an
additional $37 million in capital spending for physical security measures at its critical substations 44
In 2014, Dominion Virginia Power Company proposed increased expenses over five to seven years
to harden critical infrastructure against man-made threats Dominion's efforts, which began in
2013 at the most critical substations, included typical physical security improvements, additional
42 Sabotage puts Focus on Threats to the Grid AZcentral June 12,2014 See
http//www azcentral com/story/news/anzona/2014/06/12/sabotage-nogales-station-puts-focus-threats-grid/10408053/
43 Pennsylvania Public Utility Code 52, Section 101 Public Utility Preparedness Through Self Certification
44 Parformac,op crt p 21
14
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access control and improved physical barriers, equipment hardening, polymer bushings, and spare
equipment stored offsite 45
In February of 2012 the Tennessee Valley Authority began increasing security at its non-nuclear
infrastructure, stationing 24-hour contract guards at critical facilities, as well as improving its
surveillance method including video analytics, infrared monitoring, and enhanced coordination
with local law enforcement agencies 46
An interesting problem in western Africa is the theft of transformers for cooling oil, which
residents of the area use for a wide variety of purposes including cooking and as a salve for
wounds In 2012 Kenya Power spent about seven percent of its profits replacing transformers,
which led them to begin locating transformers in homes, higher up on poles, and in other
inaccessible areas 47
5.0. Examples of Physical Security from Other Industries
Although different industries may have different specific concerns, and different assets to protect,
the methodologies used in security planning, and the types of protections available are very similar
to those employed in the electric industry Some notable examples are described in this section
5.1. Physical Security in the Nuclear Industry
In addition to the common threats to electrical reliability, the nuclear industry faces unique
challenges because of the need for a nuclear protective system to safeguard the fissile material
Access to all nuclear plants is strictly controlled with armed guards, fences, and advanced intrusion
detections Since the terrorist attacks of September 11, 2001, the nuclear industry has concerned
itself with large airplane crash attacks
In performing their risk and threat assessment, nuclear generators divide their plants into concentric
areas of escalating security, from the outer perimeter or"owner controlled area" down to the
45 Parformac,op cit p 20
46 Parformac,op cit p 19
47 Thieves Fry Kenya's Power Grid for Fast Food Aljazeera December 28,2014
http//www aljazeera com/mdepth/features/2014/12/thieves-fry-kenya-power-grid-fast-food-
2014122884728785480 html
15
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central vital area which houses the actual nuclear material and critical controls To protect these
areas, the industry uses various tools, including physical barriers, electronic surveillance, bullet-
resisting protected positions, background checks and specialized security forces 48
5.2. Physical Security in the Chemical Industry
In 2009, the Department of Homeland Security (DHS) worked with the chemical industry to
develop a set of anti-terrorism standards The product of this collaboration is a collection of
physical security risk based performance standards and metrics for evaluating the implementation
of those standards The Chemical Industry divided asset protection and security strategy into three
main areas
1 Physical security
2 Cybersecurity
3 Security Policies, Procedures and Plans
The Chemical industry plan defines physical security narrowly, to include (1) perimeter barriers,
(2) monitoring and intrusion detection systems, (3) security lighting, and (4) security forces 49
Other entities may take a more expansive view of the definition of physical security to include
elements of cybersecurity, information security, and policies, procedures and plans so
5.3. Physical Security for the Financial Sector
The financial sector utilizes the same sorts of physical security strategies as the other industries
discussed above Layered defenses are used around critical assets and structures such as buildings
and data centers These defenses include deterrent and delaying devices such as walls, locks and
access controls, detection devices, and policies and procedures for access, as well as security forces
when needed 51
48 Nuclear Energy Institute Physical Security http//www nei org/Master-Document-Folder/Backgrounders/Fact-
Sheets/Nuclear-Power-Plant-Security
49 Department of Homeland Security(DHS) Risk Based Performance Standards Guidance Chemical Facility
Antiterrorism Standards May 2009, p148
50 Part of the Commission's task in enforcing Senate Bill 699 will be determining what falls under the rubric of
"physical security"
51 Enterprise Risk Management PC1 Security Systems 2014 See http//www emrisk com/knowledge-
center/newsletters/physical-security
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5.4. Military Physical Security
Army field manual FM 3-19 30 spells out security measures for army facilities Not surprisingly,
the field manual lists common physical security measures such as Protective Barriers, Lighting,
Electronic Systems, and Access Control 52 The field manual recommends a system based approach
including risk, threat and vulnerability assessment
6.0. Risk Based Physical Security for the Electric Grid
6.1. Risk Management Process
The risk management process is an accepted methodology used either implicitly or explicitly in
most threat prevention strategies
RU
I
IN r-
RISK
- -_ C-'77-`
�)11
0 r
The Risk Management Process53
Typically, risk management involves a process of risk and vulnerability identification and
assessment, risk mitigation or control, and a monitoring process based on performance standards
Without divulging the specific activities of any particular utility, discussions at both the open and
52 Army Field Manual FM3-19 30 2001 See https//www wbdg org/ccb/ARMYCOE/FIELDMAN/fm31930 pdf
53 Risk Management Suwanee County Florida See
http //www suwcounty org/mdex php9option=com_content&v►ew=art►cle&id=32<em►d=67
17
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closed sessions of the CPUC June 2014 physical security workshop indicated that all utilities use
some sort of risk and vulnerability assessment to plan for physical security protections, and utilize
similar physical threat mitigation techniques
6.2. Risk Identification and Assessment (Evaluate Risks, Threats, and
Vulnerabilities)
The first step of a risk based process is the identification of all potential risks, threats and
vulnerabilities, then the classification or assessment of these risks In assessing risk, evaluators
look at all potential threats, analyze the vulnerabilities of equipment to those threats, evaluate the
likelihood and impact of an event occurring related to that threat, and assign a risk priority to the
threat
Some risk evaluators use tools developed to identify and access threats One such tool is the so-
called CARVER matrix, developed by Special Forces during the Vietnam War 54 The acronym
CARVER stands for Criticality, Accessibility, Recuperability, Vulnerability, Effect and
Recognizability 55
In the electric industry, threats can be classified by the source and the methodology As to the
source of physical risks and threats, they can potentially emanate from vandals or thieves,
disgruntled employees and possibly terrorist entities The methodology of attack can include
vehicle (land or aerial) attack, human intrusion for purposes of damaging or stealing equipment,
gunshots, bombings or attacks with other weapons 56 Advanced modern forms of attack could
potentially include electromagnetic pulse weapons which can disrupt grid operations As part of
this threat identification process, and throughout the risk management process, the utility will also
look at the vulnerability of the assets to different types of attacks
54 Tucson Electric Power used this methodology in developing its plan for compliance with NERC CIP 14 Tucson
Electric Power Presentation,September 2014
55 Bennett, Brian T (2007) Understanding, assessing, and responding to terrorism protecting critical infrastructure
and personnel(2007 ed) John Wiley& Sons ISBN 0-47 1-77 1 52-X
56 A representative from Lawrence Livermore Laboratories, commenting at the 2014 CPUC substation workshop,
indicated that while possible, bombings of substations were less likely than other modes of attack
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After enumerating all potential risks, the utility will classify the risks according to probability of
occurrence and severity of impact This type of assessment generally leads to the development of a
risk matrix 57
F! t
�� Jann
i
� r
rT
Owl
Risk Matrix
Probability considerations include (but are not limited to)
1 Geographical location
2 Ease of access, vulnerability of asset to attack
3 Criticality or importance of asset to the delivery system
4 Local demographics
5 Existing natural barriers
6 National security intelligence and reports, current security climate
The probability of some specific risks may depend on specific unique factors Copper theft is
always a major issue for utilities at the distribution level Not only does this theft involve a large
loss of property, but vandals are frequently killed or injured stealing copper As a result, twenty six
states have considered legislation to reduce or prevent copper theft, primarily by controlling the
businesses that reclaim copper 58 Despite the fact that copper theft is always a problem for utilities,
the probability can be tied to specific external factors such as economic conditions and the cost of
copper All of these factors should be included in a risk management probability assessment
57 Risk Management AcQNotes 2014 http//www acgnotes com/Tasks/Element-3-Assess-and-Document-Risk html
58Copper Theft Survey Electric Safety Foundation International 2014 See http//esfi org/mdex cfm/page/ESFI-
Re leases-Res ults-of-National-Utility-Copper-Theft-Survey/cdid/10357/p id/10262
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To evaluate the severity or the impact of a successful attack, security planners consider the
potential impact of loss of a particular asset Potential results of a successful physical attack on
distribution facilities can include death or injury to the public or workers, financial loss through
equipment replacement, health and safety ramifications due to loss of power or stability in the
electric system Some impacts, such as financial loss, can be relatively easily quantified Others
are less tangible To determine the likely potential impact of attack on a specific facility or asset,
considerations should include (but are not limited to) the following 59
1 Type of facility- generation, substation, transmission or distribution,
2 Criticality of facility to operation of the grid,
3 Criticality of the facility based on customers,
4 Ease of restoration of the facility, replacement spares, cost of replacement,
5 Ability of the grid to function normally given loss of the particular asset (redundancy or
resiliency concerns) These redundancy or resiliency concerns include the difficulty of
repair, the availability of alternative paths in the grid, presence of effective remedial action
schemes, and the availability of spare parts
In general, the threat considerations and mitigation techniques for generating stations would be
similar to those for substations Generating stations contain physically larger targets (such as
boilers) and large transformers, to particular the main step-up transformer, but are more likely to be
manned and guarded Additionally, according to NERC, although it may have a significant effect
on local reliability, the loss of one generator is typically not as damaging to grid stability as the loss
of a critical transmission substation 60
6.3. Risk Mitigation (Control Risks)
6.3.1. Physical Mitigation
6.3.1.1. Mitigating Threats to Substations
Physical mitigation of threats to electric facilities includes deterrence or prevention, detection, and
response As discussed above, the Department of Homeland Security, in planning for the Chemical
Industry, defined physical security narrowly, to include perimeter walls and fences, intrusion
59 CPUC Substation workshop discussions,June 2014
60 FERC Notice of Proposed Rulemaking Docket RM14-15-00 July 17,2014 P22
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detection, lighting and security forces Expanding on that narrow definition, it is possible to
delineate general areas of physical security measures under the headings of deterrence, detection,
and response
• Deterrence (or prevention) includes, but is not limited to
o Walls, gates, locks and fencing (consider whether intrusion will be by human or
vehicle and what types of vehicles might intrude)
■ Layered concentric approach
■ Surrounding entire substation or individual equipment
■ Chain link, concrete, vinyl, metal, wood, barbed wire, razor wire, cinder
block, block, cables
■ Opaque fencing or walls to prevent visual sighting of substation equipment
o Signage
■ High voltage signs, guard signs, signs indicating existence of cameras
o Guards
■ Manned stations, patrolling, specially trained guards
o Lighting
■ Properly designed lighting both deters intruders and makes intruders easier
to identify
o Vegetation management
■ Removal of attacker concealing shrubbery from perimeter of substation,
removal of shrubbery from substation fencing
• Detection (Monitoring) includes
o Cameras
■ Video, pan-zoom-tilt, inward pointing or outward pointing61
o Intrusion detection
■ Infrared, Motion sensors, fence mounted, beam sensors, open area sensors,
acoustic
o Gunshot detection
o Aerial surveillance, manned or unmanned
61 As part of its strategy following the Metcalf incident, Pacific Gas and Electric decided to change its focus to increase
both inward and outward pointing cameras to detect threats Substation Workshop Comments,June 2014
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o Analysis of unusual or increased traffic patterns or other activity near electrical
assets
o Equipment alarms (in conjunction with intrusion or gunshot detection can indicate
presence of attack or malevolent actor)
■ Low oil alarms (can indicate gunshot), temperature alarms, ground fault
alarms
■ Gate or door alarms
■ Alarm interpretation and integration systems, control centers to eliminate
human error
In addition, utilities may need systems to interpret alarms from detection equipment For example,
a detected gunshot followed immediately by some sort of equipment failure alarm may represent
gunshot damage to a piece of equipment Similarly, an intrusion alarm followed by an equipment
alarm may indicate a vandal removing equipment or copper In these instances cameras can also be
used to attempt to identify the exact nature of the attack
• Response (minimize effects of attack)
o Advanced technology
■ Self-sealing transformer, hardened equipment and cooling systems, gunshot
resistant polymer bushings
o Improving Resiliency
■ Multiple alternate paths for delivery of electricity
■ Effective remedial action schemes to minimize effect on other facilities
o Improving Restoration62
■ Ready spares
■ Cooperative agreements for manpower and equipment sharing with other
utilities
■ Advanced communication systems (SCADA, microwave)
■ 24/7 monitoring of alarms
62 The CPUC staff report on the 2011 Southern California Windstorms, Investigation of Southern California Edison
Company's Outages of November 30 and December 1, 2011,recommended several areas of improvement for Southern
California Ed►son's(SCE's)emergency response procedures Additionally, CPUC General Order 166 requires utilities
to prepare emergency response reports
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■ Drills with local first responders
■ Emergency planning
• FEMA Incident Command System(ICS) and National Incident
Management System(NIMS) training and programs
6.3.1.2. Mitigating Threats to Overhead and Underground Facilities
In a February 2014 article on the PG&E Metcalf Substation attack, the Wall Street Journal
reported
"Overseas, terrorist organizations were linked to 2,500 attacks on transmission lines or
towers from 1996 to 2006, according to a January report from the Electric Power
Research Institute "63
In the United States, underground and overhead electric facilities regularly sustain damage from
vandals and thieves, if not from terrorist entities However, sophisticated mitigation and
prevention is not as critical because spares and repair staff are nearly always available With
exceptions, electric utilities also maintain some redundant paths for delivery of power at the
transmission and distribution levels
A 2006 California"heat storm" which resulted in overheating damage to numerous distribution
transformers, and a 2011 windstorm in Southern California demonstrate that widespread damage to
overhead or underground distribution facilities can cause extended outages and significant
restoration costs However, the sheer number of these facilities renders them difficult to protect,
while the availability of more attractive targets such as substations makes overhead and
underground distribution facilities less likely to sustain a terrorist attack Rather than trying to
completely protect each pole or tower, utilities typically concentrate on maintaining spares and
developing effective restoration plans
Still, some cost effective mitigation efforts are advisable, and in some cases mandated by existing
Commission rules, specifically General Orders 95 and 128 These security mitigation efforts also
help from a safety standpoint Typical mitigation efforts for these facilities include
63 Smith, Rebecca "Assault on California Power Station Raises Alarm on Potential for Terrorism" Wall Street
Journal, February 5, 2014
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o Removing pole steps to make poles more difficult to climb
o Climbing guards on tower and lattice structures
o Locking devices on pad mounted transformers and switches
o Fasteners on vault covers
o Over-insulation on transmission towers including oversized or redundant insulators
and gunshot resistant polymer insulators
o Signage warning of shock hazard or in some cases surveillance
Additionally, given the existence of important, high capacity submarine cables, such as the Trans-
Bay cable, utilities should include the protection of these assets in their security plans where
applicable
6.3.1.3. Spare Parts Programs and Planning
An electric substation typically consists of transformers, circuit breakers and relays, which provide
protection for the power lines and substation equipment, batteries for back-up and to operate the
relays, and other ancillary switches, buses and equipment Because a substation contains large
pieces of important equipment in a centralized location, it could be an attractive target for thieves,
vandals, and other malevolent actors The substation power transformers are of particular concern
in security planning because they are critical to the operation of the substation, are large targets,
with several areas of vulnerability (bushings, oil tanks, controls), in general are unique to the
substation, are costly and require large leads times for replacement According to the United States
Department of Energy, lead times for high voltage transformer replacements can vary from 6 to 20
months, and each transformer replacement can cost over 10 million dollars each 64
For large items such as transformers, utilities may maintain formal and informal sharing and
cooperative arrangements with each other Some formal sharing agreements also exist under the
NERC Spare Equipment Database and Edison Electric Institute Spare Transformer Equipment
Program 6s
Other assets in the electric system include poles, towers, lines, bushings, small transformers and
capacitors, and associated equipment For such equipment in the lower voltage distribution system,
64 Parfomak, op cit, p 4
65 Electric Power Research Institute Power Transformer Emergency Spares Strategy October 2014
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utilities typically maintain a significant number of spares Additionally, distribution level parts do
not typically present the logistic and lead-time problems associated with transmission level
equipment 66
6.3.2. Policies and Procedures Related to Physical Security
Utility policies and procedures should support the physical security measures These policies and
procedures include background screening of personnel, training, access control processes, and
drills and exercises
Given the complexity of modern technology used in security systems, training of guards and
security control center personnel is crucial Additionally, these security employees (or contractors)
must be provided with clear policies and procedures PG&E's summary report on the causes of the
breakdown in security during the Metcalf burglary identified training and updated procedures as
key action items 67 All training programs and policies should be reviewed regularly Training
programs should include employee testing, and retesting on regular basis, and must include
provisions that stimulate real-world scenarios if possible
All protection equipment such as alarms, intrusion detectors, lights, and cameras should be
properly maintained and tested frequently Thorough preventive and predictive maintenance
programs should be developed for the security of such equipment Some testing and inspection
should be performed as part of routine substation inspections To dissuade thieves and vandals,
valuable material should never be stored in plain sight in a substation
6.3.3. Other Considerations for Risk Mitigation Planning
6.3.3.1. Cost Considerations
Any security mitigation plan must take into account the costs involved In particular, for investor
owned utilities which must recoup costs through rate mechanisms, it is important to consider the
cost of security measures to the end customer Tall walls, large security forces and advanced
technology might provide the ultimate in security but in many cases will be excessive, and will
present an untenable burden, particularly to low income residential customers
66 Discussion at physical security workshop CPUC June 2014
67 PG&E Metcalf Root Cause Analysis Summary report November 21,2014,p6
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As part of that consideration, the utility must not only take into account the nature of threats and
the type of facilities it owns, but the nature of its rate base and the cost which the customers can
support Every decision should include the consideration of multiple alternatives, and a cost-
benefit analysis Some costs, such as the price of a wall or the actual replacement cost of an asset
damaged by a successful attack, are clear Tools and rubrics exist for calculating the numerical
cost of loss, including Annual Loss Expectancy calculations 68 Devastating losses, such as loss of
life, and other intangible losses, such as organization reputation, are more subjective Accounting
models exist for comparing alternative expense choices and evaluating long and short term costs as
well as opportunity costs
For example, in Southern California Edison's (SCE's) 2015 rate case, SCE analyzed the costs and
benefits of utilizing advanced security guards, compared to an alternative approach of utilizing
some security guards along with detection equipment and software analysis 69 SCE determined it
could achieve significant savings without sacrificing security by using the combined approach
Finally, when utilities perform risk-benefit studies, they may perform more comprehensive
analysis, considering security risks as part of the entire constellation of risks to service, such as
extreme weather events, earthquakes, or failure of other facilities which may affect the
performance of the facility in question 70 The CAISO typically performs its reliability studies in
this manner
6.3.3.2. Environmental Impact Considerations
Investor-owned utilities are required to obtain permits from the CPUC for construction of certain
specified infrastructures listed under Public Utilities Code (PU Code) sections 1001 et seq,
including distribution facilities 71 Typically, as part of the CPUC`s permit application review and
decision-making process, the CPUC, as the lead agency, conducts an environmental review
68 Malashenko,Villareal and Erikson Cybersecurity and the Evolving Role of State Regulation How it Impacts the
California Public Utilities Commission September 19,2012, p3
69 SCE General Rate Case 2015 Testimony SCE-07, Volume 4, p 41
70 For example,failure of a gas delivery system may affect the reliability of a power plant These considerations are
known as"co-located facility" considerations
71 The CPUC reviews permit applications under two concurrent processes (1)an environmental review pursuant to the
CEQA, and(2)the review of project need and costs pursuant to PU Code sections 1001 et seq and General Order
(G O) 131-D(Certificate of Public Convenience and Necessity(CPCN)or Permit to Construct(PTC))
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pursuant to the California Environmental Quality Act (CEQA) 72 The CEQA process requires the
lead agency to identify potentially significant environmental impacts to several impact areas, and to
avoid and/or mitigate any environmental impacts found to be significant If the CPUC approves the
permit application, it issues a decision approving the construction, which would adopt
environmental mitigation measures and a mitigation monitoring plan
This section discusses common CEQA environmental mitigation measures related to distribution
facility and substation projects that may need to be considered in utility distribution system
physical security planning One should keep in mind that CEQA mitigation measures are project
specific and the discussion in this section is a general approach to environmental consideration
when developing physical security plans When assessing environmental impacts under CEQA, it
is often determined that the introduction of a new land use, such as a substation, to the project area
would result in land use changes/impacts as well as potential long-term visual quality impacts to
the surrounding area Generally, a new substation would result in the degradation of existing visual
character/quality of the substation site and its surrounding area, or the creation of a new source of
light or glare that would adversely affect day or nighttime views in the substation area 73
Common environmental mitigation measures for preserving existing visual character/quality
require the project proponent to establish a landscaping and maintenance plan for a permanent
vegetative screening and to coordinate with local land use planning department/agencies to ensure
consistency with applicable visual resources goals and policies The following common mitigation
measures could be part of the landscaping and maintenance plan developed by the project
proponent and submitted for review and approval by the relevant local agency, such as the city,
county, or other agency with land use jurisdiction
• Vegetative screen of sufficient height and density to provide for visual screening around the
substation and all substation components, consistent with safety, feasibility, and
engineering requirements
• Visually opaque gate at substation entrance to obscure views through the gate from the
substation site entrance road
72 The CEQA Guidelines are codified at Title 14 California Code of Regulations section 15000 et seq
73 Appendix G of the CEQA Guidelines identifies the circumstances that can lead to a determination of a significant
impact
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• A perimeter wall of sufficient height to obstruct views into the facility, in addition to
exterior landscaping
To address the environmental impacts created by a new source of light or glare from the substation
that would adversely affect day or nighttime views in the project area, mitigation measures for light
and glare might ensure all lighting is shielded, directed downward, and of minimum brightness
necessary for safety, and that no direct or excessively bright reflective light would be present off-
site, as follows
• Shroud and minimize unnecessary sources of light Design and install new permanent
substation lighting such that light bulbs, lenses, and reflectors would not be visible from
public viewing areas so that the lighting does not cause reflected glare and that illumination
of the project, vicinity, and nighttime sky is minimized
a Lighting could be designed so exterior light fixtures are hooded where possible,
with lights directed downward or toward the area to be illuminated and so that
backscatter to the nighttime sky is minimized
b Design of the lighting could be such that the luminescence or light source is
shielded to prevent light trespass outside the project boundary
• Lighting could be restricted to the minimum necessary brightness consistent with worker
safety and Occupational Safety and Health Administration (OSHA) requirements
• Lighting could be kept off when the site is unoccupied in order to minimize nighttime sky
illumination, and could only be switched on during the nighttime in order to perform
maintenance or outage repairs
As stated above, this discussion is intended to be general and to highlight common environmental
mitigation measures that may need to be considered as part of physical security planning for
distribution facilities However, as part of the rulemaking for rules for distribution physical
security, the CPUC may ask the parties to review CEQA documents and other sources to determine
other applicable environmental impacts and mitigation measures for consideration
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We note that, in a CEQA review, the safety impacts of potential environmental mitigation
measures should be an important consideration in assessing their feasibility With the increased
emphasis on physical security, perhaps there will be creative developments in measures that
mitigate environmental impacts without creating security concerns
6.3.3.3. Miscellaneous Considerations
Some other considerations in development of physical security plans include local geography and
demographics, customer base, facility design, environmental rules and considerations beyond
CEQA requirements, local codes including aesthetic considerations, and the population in the
vicinity of electric facilities
To incorporate these considerations, the utility should use sound engineering judgment, experience
and consider the national security climate
6.4. Metrics (Review Controls)
The risk management process is a dynamic methodology Along with identifying and assessing
risk and developing and implementing a mitigation strategy, security planners should develop a set
of metrics to determine if their strategy is optimal, and use these metrics to make strategic
adjustments where necessary The use of metrics also becomes critical in the context of regulation
which will be, at least to a certain extent, performance based
6.4.1. Prescriptive versus Performance Based Regulations
In general, two possible models exist for regulation—a strict prescriptive approach, or a
performance based approach Under a prescriptive approach, the regulation requires the utility (or
other regulated entity) to comply with specific design or operational requirements In other words,
the regulation dictates exactly what actions the utility must take to remain in compliance, and
exactly "how" the utility should perform these actions In a performance based regulatory
structure, the regulation does not specifically detail "how" the utility must comply, but requires
instead that the utility must address a certain issue (such as physical security or environmental
requirements), and must meet certain performance metrics
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For example, a prescriptive environmental regulation might require all electric generators to be
built with selective catalytic reduction equipment to control emissions A performance based
requirement might require the utility to develop an emission control plan that reduces emissions to
a certain level or by a certain amount
Electric distribution systems differ immensely from one utility to another Geography, weather,
local construction codes, size of territory, demographics of area, types of customers, and design of
substations and other facilities vary significantly, particularly between small, mainly rural utilities
and larger, urban utilities
Because the nature of utility physical security is not one-size fits all, a prescriptive approach can
have some major deficiencies
• Some prescriptive requirements might be applicable to some facilities and not others,
• Security, technology and best practices rapidly evolve Prescriptive rules could impose
inefficient, ineffective, and out-of-date requirements,
• Prescriptive requirements may not address significant new threats,
• Prescriptive requirements could require almost constant revision
For these reasons, a performance based approach is often more effective than a prescriptive
approach Under a performance based approach, the compliance of the security plan is based on
how well the implemented plan meets metrics established by either the utility itself or a regulating
body
6.4.2. Control Metrics for Utility Distribution Systems
Control metrics can include both quantitative or statistical metrics and qualitative performance
metrics Examples of quantitative metrics for distribution physical security measures include
tracking copper theft, successful or unsuccessful intrusion or attack, false or nuisance alarms,
condition of all monitoring equipment, performance of security personnel in training exercises and
on tests, results of substation inspections including number of problems found with condition of
deterrence and monitoring measures, instances of vandalism or graffiti, problems with access
control, number of malfunctions of security equipment, or camera coverage Of course, any
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attempted or successful attacks should be reflected in the metrics Resiliency and restoration
capabilities can be tracked through outage restoration time data and asset loss simulations 74
One example of qualitative metrics is using a subjective expert analysis to compare a planned or
existing protection scheme to a developed standard metric For example, for efforts to detect
threats, the Chemical Industry compares programs to various standard "tiers" of acceptability The
industry describes the lowest"tier" of acceptability (Tier 4) as
The facility has some ability to detect attacks at early stages
The highest tier (Tier 1) is presumably the "gold-standard" in attack detection The Chemical
Industry describes this level of protection as
The facility has a very high likelihood of detecting attacks at early stages through
countersurvecllance,frustration of opportunity to observe critical assets, surveillance and
sensing systems, and barriers or barricades To achieve this level of detection, a facility
could,for example, maintain a facility-wide intrusion detection system that is continually
monitored from a Security Operations Center and has an adequate backup capability 75
In addition, utilities can develop various test scenarios or exercises and evaluate the performance of
their security systems under stress These can include both tabletop and actual attempts to breach
the security system to determine its effectiveness Because large scale attacks are rare, the utility
should simulate attacks or other actions such as third party surveillance of a station or other asset,
and record quantitative metrics from these tests
Finally, an analysis of any security related findings from facility insurance inspections (often
conducted by independent security and risk experts) or internal utility audits can provide both
quantitative and qualitative indications of the effectiveness of existing security measures
74 Evaluating utility benchmark outage data such as the Customer Average Interruption Duration Index(CAIDI)can
provide an indication of potential restoration time after any event
75 Department of Homeland Security(DHS) op cit p 58
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7.0. Proposed Next Steps for the Commission
As stated above, existing Commission rules have long addressed electric distribution system
physical security The attacks on the Metcalf Substation make it apparent that there is a broader
role for regulatory oversight in this area Because of new state requirements pursuant to Senate
Bill 699, the path forward for the Commission is somewhat clear, at least initially Senate Bill 699
(amending Public Utilities Code Section 364) requires the Commission, by July 2015 to imtiate a
proceeding to develop rules for addressing physical security risks to the distribution systems of
electrical corporations Section 364 further states (in part),
The standards or rules, which shall be prescriptive or performance based, or both, and
may be based on risk management, as appropriate,for each substantial type of distribution
equipment or facility, shall provide for high-quality, safe, and reliable service
and,
In setting its standards or rules, the commission shall consider cost, local geography and
weather, applicable codes,potential physical security risks, national electric industry
practices, sound engineeringjudgment, and experience
7.1. Development of Rules Required by Senate Bill 699
7.1.1. Potential Model for Rules for Physical Security
Given differing geographical locations, designs, cost considerations, and other factors, it would be
imprudent to rely solely on prescriptive "one-size fits all" physical security requirements for
distribution76 facilities for all electric utilities Instead, a risk based-performance approach, similar
to that seen in the chemical industry, is one feasible approach 77
76 Note that while Section 364,mentions the"distribution"system,the statute does not define the term As part of the
rulemaking process,the Commission should decide what sorts of facilities the new rules apply to This could include
all substations and power lines at all voltage levels, as opposed to only those lower voltage facilities typically
considered as"distribution"assets
77 What is presented here is only one potential model for enforcement of the changes to PUC Section 364 under Senate
Bill 699 The final decision will be based on a rulemakmg proceeding,potentially with stakeholder workshops
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Electric utilities already evaluate risks in security planning It is likely that all electric utilities will
consider similar threats and risks, and utilize similar considerations (cost, resiliency, restoration
difficulty) in evaluating those threats
However, because the Commission has certain mandates from new and existing legislation, along
with certain established priorities (e g , cost considerations and environmental protection), a hybrid
plan, including risk based performance rules with some general semi-prescriptive guidelines, may
be optimal
The new NERC CIP-014-1 standard, along with the processes developed under CPUC General
Order 174 for Substation Inspections and CPUC General Order 167 for Power Plant Operations
and Maintenance present good potential starting points for an enforcement model
Under NERC CIP-014-1, bulk power transmission owners are required to identify critical
substation assets, identify and assess risks to those assets and develop a unique physical security
strategy to mitigate those risks The NERC standard mandates that each step in the process be
vetted by an independent expert
General Order 174, Rules for Electric Utility Substations, requires each utility to develop and
follow an inspection program for its substations, and to update that program as necessary The
General Order requires utilities to follow accepted good practices in the development of these
programs, and Commission Decision 12-10-029, which approved the General Order, required the
electric utilities to establish these accepted good practices, along with Commission staff, through a
series of annual workshops Finally, General Order 167, Enforcement of Maintenance and
Operations Standards for Generating Facilities, represents a performance based standard with a set
of guidelines
A potential structure for rules to be considered pursuant to the new requirements in Public Utilities
Code Section 364, adopted pursuant to Senate Bill 699, could require each electric utility to use a
risk based approach to identify and assess risks to its distribution system, and prepare and follow
plans to mitigate those threats The electric utilities could be allowed to decide to evaluate each
asset separately, or develop a tiered system of protection and classify assets within that system
The Commission could also require the electric utilities' plans to meet certain general guidelines
(see Section 7 1 1 1 below)
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Potentially the Commission could require security plans to be vetted by established security
organizations, which could also provide expertise on protection of sensitive information
A critical portion of a utility's plan would be the development of metrics and consistent testing of
the effectiveness of the plan The Commission has some guidance with respect to metrics in the
DHS Chemical Industry Risk Based Performance Standards However, the electric utilities should
propose quantitative metrics for the electric industry The metrics should include testing and drills,
including surprise drills and simulated attacks, to evaluate and monitor the effectiveness of the
plans For such tests, the utilities should utilize outside expertise where necessary
Under this suggested model, some electric utilities might not need to make changes to their
existing physical security measures For many small distribution substations, typical physical
security protections are limited to chain link fences topped by barbed wire, signage, locked gates,
appropriate lighting, alarms and access control policies They may include a camera or simple
intrusion control device For such substations, these security protections may be adequate and the
electric utility might not need to upgrade or change them The proposed model would, however,
require the electric utilities to justify their new or existing security measures using a risk based
protocol
Of course, if a thorough risk based analysis identifies any deficiencies in existing physical security
measures, the utility must make the appropriate material changes to bring its facilities into
compliance
7.1.1.1 Guidelines and Industry Standards
Along with this performance based model, the Commission should adopt at least high level
prescriptive guidelines It is impossible for Commission staff to inspect and evaluate the security
needs at the thousands of substations in the state However, the Commission can adopt guidelines
for the development of the plans
Potential guidelines to consider including along with the risk based process requirements might
include
o The utility physical security plans should include strict timelines for implementation
of the plans
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o The utility physical security plan should include consideration of risk and
vulnerability to communication facilities necessary for effective operation of alarms
and monitoring equipment
o Relevant cybersecurity measures should be designed into the physical security
program
o The utility should consider manning or guarding some assets, and provide a clear
Justification for when such measures are necessary or unnecessary
o The utility should provide a clear justification for perimeter boundaries, such as
walls and fences, which includes an analysis of the types of vehicles which might
attack and at what speed
o The utility should explain its choice in monitoring and intrusion detection equipment
given the location, geography, threat profile, and demographics of the area The
utility should present a plan for consistently inspecting and testing this monitoring
equipment under simulated real life events
o The utility should develop preventive maintenance and inspection programs for all
physical security related facilities, structures and equipment
o The utility should perform lighting studies at all facilities to determine the optimal
lighting system to deter attacks
o The utility should perform a full analysis of vegetation present in the vicinity of the
facility and the threat it poses to the physical security
o The utility should consistently test its alarm systems and any alarm interpretation
software It should consistently work to eliminate false alarms
o The utility should look at each asset separately and determine the effect on the grid
of the loss of that asset, and the availability of spares and estimated restoration
times
o The utility should review its emergency response and preparedness and business
continuity planning in conjunction with the development of its physical security
plan
o Where appropriate, when developing physical security plans, utilities should
consider any special implications related to the protection of modern grid assets
including, but not limited to, communication and control devices such as phase
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measurement units, gas insulated substations, inverters, energy storage devices and
other distributed generation components
o The utility should include physical security equipment, policies and procedures in
any corporate quality assurance (QA) and continuous measurable improvement
(CMI)programs
o The utility plan should include an effective root cause analysis program for
analyzing security failures, including failures during testing and drills
o The utility should look at each piece of equipment in the substation or comprising
any other asset separately and determine what the threats to that piece of equipment
are, and what vulnerabilities exist For example,
■ What is the most critical piece of equipment in the substation? What is the
most vulnerable? The transformers? The batteries? The bushings? The
cable terminations? The relay room?
■ What are the major modes of attack on those pieces of equipment? Does the
mode or method of attack change depending on the season, or the time of
day
■ What are the possible modes of protections for those assets and what are the
costs? Does the criticality of the piece of equipmentjustify the mitigation
cost
The Commission should require that the electric utilities demonstrate they considered cost,
environmental impact, existing threat levels, national security information, and other important
variables identified in Senate Bill 699 and discussed elsewhere in this whitepaper
The Commission could also require the electric utilities to follow directives of industry groups such
as the Institute of Electrical and Electronics Engineers (IEEE) Substation Physical Security
standard, which focuses on theft and vandalism 78 Both FERC and NERC have developed
guidance and best practice documents related to physical security, primarily for the bulk power
grid In 2013 and 2014 FERC staff, along with other energy industry and security agencies, held a
series of meetings with utilities and law enforcement to discuss physical security of the grid In
78IEEE Standards Association 2014 See http//standards ieee org/findstds/standard/1402-2000 html
36
ALJ/GK1/jt2 `
2013 NERC published its latest guidelines on physical security, Security Guideline for the
Electricity Sub-sector Physical Security Response 79
The Commission could also mandate ongoing workshops to determine accepted good practices in
this area, as it did in Decision 12-10-029 adopting General Order 174 for substation inspections
At a later date the Commission may decide to add more specific prescriptive guidelines or
requirements (e g , all facilities of a certain type must utilize a particular deterrent or detection
measure) Regardless of whether these new regulations contain requirements for information
sharing between utilities, the electric utilities should consider developing a forum for sharing best
practices and lessons learned
If the Commission requires the utilities to develop and submit physical security plans, Commission
staff could review the plans and utilize existing industry standards to determine if the plans meet
the requirements of Public Utilities Code Section 364 and any implementing Commission decision
Commission staff could physically inspect security measures as part of routine substation or
distribution audits, or in new focused security inspections The Commission might consider
contracting with third party security experts in these evaluations or for training of staff to perform
these evaluations In addition, Commission staff may observe drills that the electric utilities
conduct to evaluate the effectiveness of the physical security measures adopted
7.1.2. Protection of Sensitive Information
Given the Freedom of Information Act and the California Public Records Act, along with
Commission policies in favor of greater public disclosure,80 a major concern expressed by the
electric utilities during the CPUC June 2014 workshops is the confidentiality of security and
business sensitive information The Commission could limit the information that must be given to
the Commission to only the information necessary for the Commission staff to perform their work
Additionally, Senate Bill 699 allows the Commission to redact sensitive security information from
public disclosure
Utilities submit confidential information under the provisions of Public Utilities Code 583 and
General Order 66-C, which identify certain information as exempt from public disclosure
79 Parformak, Paul op cit, p 17
80 See Resolution L-436, Resolution Regarding the Disclosure of Safety Related Records, February 14,2013
37
ALJ/GK1lt2
requirements It is important that all documents receive careful scrutiny before any public release,
to avoid disclosing sensitive infrastructure information
A Commission whitepaper on cybersecurity expressed similar concerns 81
In order to lower the risks and barriers to sharing information with Commissioners and
CPUC Staff, safe harbor provisions may be useful to open up lines of communication
between utilities and the CPUC Safe harbor provisions, coupled with new protections
around public disclosure of sensitive data, could result to a beneficial exchange of
information and a greater openness between utilities and the CPUC
Information regarding distribution assets might be less likely than other system information to fall
under the protections of the Protected Critical Information Infrastructure (PCII) program 82
Regardless, it might be helpful for staff to obtain PCII training and certification
The Commission might wish to solicit outside organizations, e g , think-tanks or other
governmental agencies, to review the Commission's procedures for handling sensitive information
8.0 Conclusion
Recent events and increased public awareness directed toward electric grid security, as well as the
limited breadth of federal standards, make distribution physical security an important issue at the
state level Recent California state legislation requires the Commission to develop rules for
distribution physical security Given the wide array of threats, equipment designs, and financial
abilities within the utility industry, a completely prescriptive regulatory framework is likely not
workable Therefore, the Commission should consider a hybrid risk informed, performance based
approach, with high level prescriptive guidelines Under this model, the electric utilities should
develop security plans for their distribution facilities along with metrics to evaluate the
effectiveness of those plans These plans should meet accepted industry best practices Each
electric utility should submit its physical protection plan to the Commission andjustify its plan
81 Malashenko, Villareal and Erikson Op c►t p16
82 Protected Critical Infrastructure Program DHS 2014 See http//www dhs gov/protected-critical-infrastructure-
information-pcii-prograrn
38
ALJ/GK1/jt2 `
using a cost-benefit analysis employing risk management techniques The electric utility should
also report annually on its compliance with the Commission's rules, as required by Section 364
After determining the type of facilities to be covered by the Commission's rules, the Commission
should require each utility to
• Develop risk based physical security plans for its facilities Plans should include
preventive maintenance programs
• Justify those plans based on current industry best practices and a thorough risk
assessment
• Potentially utilize independent third party security experts to prepare and vet the
plans
• Present a schedule for implementation of the plans
• Consider multiple alternatives and include metrics for evaluating the efficacy of the
plans The metrics should be quantitative where possible, and the utility should
develop tests and drills to stress and evaluate the physical security plan
• Submit the plans for approval by the Commission
39
ALJ/GK1/Jt2
Appendix A
Sert�ie BID N(L 6"
C:I"IAFyMR kO
An aet m ameM Section A4 of the Public Utilities Ctade mlarina to
public utilities ~
IAPFrv-d by(➢wenvu bapmmb+CV 75,701 a Filed witli
Se�swrq vtStaie SaFec,ubar'�S::P{d,l
legislattvc counsel s digc$t
SB 699;Mt I Public uuhtt r electrical corponuianf
t$ndercxisiiitg-law, 'thc"Public Utdtues ConiTuision hiaa,regulaton
autharity over public ecaporatianv,,as drf,riccl
t�uetiflg'tan t+xptiitls ibe.enmmissta t to adopt irnpeeam•m;Qatenimce,
repair.and replacement stan'rds fgr the dtstriAuunrt sy iterrts of ejeatncztl
"cor}mmtirina;m cr trtpt tde`high quality,-wrc,and reliable servioo.
Exi4mg'lau requires the cantraiNsiam to conduct ri rmew to detararinc
u hcther the standards have bccn met and to perform the?aiew after every
major outage
Thw bill woulCl raqutte,the commission,In a new"prviceedin&or new
ptwsc,of an existzng proceedscl,to'cornmetice en�lxlora Jv}y 1 2,i115.
to consider adopting rulr-s' to,addrms,physival,,Kcurity rLs4 to the distribution
tsvvcrn.*c`ufclecincal corporrstion�:
Under existing lace,a violitttan of the Pubifo UtiWen Act at anv order,
dewim tul, dvv*tion,deinaiid,or r�qutrement of th,,cottttntt3"is a
crime.
Because.the pro%isioni of this hill are within the acCand require action
by the comnaLwion to implerneat its requtrementS a violation of these
provi�woutd impose a-itate•manii.`ited IecaI program by ext vndtil$the
definition of a civnc
'lam California Canstttutirm_regt>¢t€s% e state 1�rramhursc local 4i ncics,
and school districts far certain costs mandated by the state Stttiuiory
proviskirts establish procedures"for mmking thst mnrnbursvrcna,
This bmll'u nutd provide that n4 reimburs"i is required by"this act for
ii up"tfied renion"
The people of dra Srara of Caftfornrn c enact asfollawS:
SECTION 1 The legislature iiiitis and decfares all of the fntic�wiing-
(a) Ph}"smcal threats to 4w elcctricnl drstnbutim sysisn pr€amt nsks to
public health and safety and could disrupt ceanar me activity in California
(b)"ring hpproprtatc acttam lire to rn to protect and sc�curc,srittagable
electrical&*ibution s`stun a$sets from phys'ica I thrents that could disrupt
40
ALJ/GK1/It2
C1,550 —2—
safe and reliable electric service or dtsrutrt essential public services,
including mfa drinking water supplies,are in the pu-blic Interest,(e) @meer plrnntng,in citordination with the appropriate federal and
suite regulatory and taw enforcement'aushonties.wiitl,help prepare for attacks
on the aIoctricatl&trtbution systam andd drerei6y help itiduce the potential
conscquertccsaf such-attacks
SAC ` 3ectida 364 of the 1'edrllc tTtsliitcSlCude to smcrosled In rcad,
RAC (a) The commission shall addpi inspratron,maintenance repair,
and'replaceunent standards,and shalLin a new proceedine or newphase
at'ttn a tisuag 1?rpwcdin�,to commenccon orhefore Juiy-I,2<"tl 5,ccnstdca=
adopgnt rules to address the phy�ical,security rk"to the distribution
system's of etezffical cvrporattens The standards or rules.which shall lie
prescriptive rir performance baasod,m both,find may he,basa_Yr on nsk-
manatgemenit,-as appropriate, fair each substantial type of distribution
equipment or facibty,shall protitdefor huh-quality,safe,and refieble,
san ice
(b) In seturrf its staridards otr,nile&,,tfie commissicriNhdll consider test,
local geo4raphv and a veather.,bpiyltcabt codes,pott'ntlal physical ii cz=- ty
ns1,s na'trenal cfoclric-tndustry practices,sound enguieeringjudfimcsit,and
e"penentc.The�commissrxn shall also adopt standards for oper.stiorf,-
reliability, and,safety)during periods of emergency and.disaster Ci?e
conumsaron'shall require ea Js,etectriral;oorpbratinrt to rep!?irt-aanually on
its complja�me with-thestandards or rules.ExcepLas provided in subdivismia
(d�that apart shall'bc made available to the'public
(c� The commission shall condua a review to determine whether the
sLandarrLi or rules prescribed in dtiq section hate been mcc.ffthe'commission
finds ilsat the standards or rules have not been-met,the commission may
oMcr appropriate-An6rom, tclu4Ctlxs pennitle�in the form qi:M_roducdons
or monetary fines.The mic-;y shall boptrformod after cucry major outage-
Am money,collected pursuant to this subdivision shall be used tQ-ofisd
funding for iho Calif6truit Alternative R.ktes for Energy PivW;im,
(al) The`commtsstam may, conutstant with other prrnisions of late,
withhold frorif the pubii4 info triziflon gtuter.itbd or obi irn6d puar�ua nit tu'thrs
sei:tion that itdeamn'cvoruld EOM a I,4eurity thra;�Lto the public tf rhecloxecl.
SECA \o reimliursement is required by this act pursuant to Seetiron
6 of Arti6:,N T B'of the Chliforrila Conaiitution hecaite the 6niv casts owL
may tieinctured by a Iocal,agency ar school distract will be incurred boEause
this aci-crcytes a new crimp or infrnciran;c limt iat�a i<itme or-infractions
or changes the pemiry4or a crime or-infrsctian,tyrthin the mcaning,af y
Section 17556 of the Gmernmew Code,ourharngcs the definition of a crime
wiihin that meaatwng W Section 6 rArtt4le }01[13 of ibe Califurniat,
Caaistitutian,
41
ALJ/GK1/It2
Appendix B
Pacific Gas and Electric Company;
Su ® Re L30 '11 a inci Ratrfew°
Meta;Aif Sub-stntlon
AB-requested,by the4Safety snli Enforcement Divrsron of the Caldomia Public Ufififiss
CommissIon'(CPUC),Pacific Gas and Electric Company(PG14E) is provrdfrija root cause
analysis about the burglary that oc,.erred at the Wicatf substation,in August 2014,including an
overview of th®'actlons and enhancenionts the company has-put in Wee since the initial April
16;2013;attack on the f6cility
Substation physical security is one of thelmost important issues facing gnd operators and PG&E
understands how imperative 4 is to implement strong rriessures to-protect cntka)substibons.
PCB&E-is currently in'the,Wst year'of a three-j ear plan to invest mare mifllan-W '
significantlyupgfade security at our critical facilities following last yc+ai's Attack Maior'ebeme is
of the plan related to phystcal;socuriry wwre 16 the,p�ocoss of_belrig tmplomentod at ttio t6w of
the August burglary Hov tavar,`same security rrioasuras viat are part of our plan are sti0 in
process and were not in placii to help pravent,a
The burglary that occurred at the Metcalffacility in August:2014 underscor6d the need for
a"ddidonal focis on tralning'and'suoe�Ion to support the work being-done td upgrade
technology and physical dotorronts st facilities.As a result, PG&E is r6p46ritizing training and
augmenting security suparvfsion to prevent a Similar incident.
The"root causd analysis,contains'detaRod;confidential information about aspects of`the security
measures PGr&E takes at its facilldi"and has therefore been sent to the,CPUC under
confidential protoct*6n Given the appropifete need for the public to have access to Information
about the tvyo inddonts and the steps PG&E Is taidng to safeguard critical,infrastructi re,'PG&E
has developed thls pu611c;summary report to outitrio the company,"s findings
This summary,report irictudes
• An overview of the events around the Apnl 16 2013.Metcalf,attack
• Action'sfepx taken after the_Aprll 16.2013:f,Ratdapattaok:
• An overview of the events around tho,August 26-•27,,2014,Motcalf burglary:
• Synopsis of the root cause analysis.pstformed by the company after the August,26—27,
2014.,Malcaff burglary:and
• Additional action slaps token since the August 26—27,2014,Motcait burglary
Summary Report far`Metcalf Incident Review 1
42
ALJ/GK1/lt2 `
Pacik Gas and Electnc Company
April 2013-incident at Metcalf 5ubstatton and Coumterrrieasures Taken
And 16.2013. In1*1ent Qverview:
Qn April 16,2013,gunshots caused extensive damage to the Metcalf Transmission Substation
south-of Sari Jose No one was hurt'and no customers`lost power as'a result of this incident
PG&E-'s Transmission Control Center operators reactod to alarms and worked to avoid sennoe
interruptions for PG&E's customers Gre4 also arfnred cm site to assess"full Impact of the
damage grid begin repairs PG&E's eledrlc system co'rdains signfficant redundancies that aiksw
the compariy to reroute end'shi t electnc load Awn equipment is damaged Those,
redundancies worked as designed.,
Following the incident,PG&E worked vith federal,state and locai,agencias,as well as outside
consultants to take-intsdm,stao 66 itr9mve substation security vvh le develbping a thre"ear'
plan to enhance security at aritical'substatiohs,
• PG&E deployedtsecunty guards to prow cli,241t presence at critical substations and
increased patrols from local law enforcement,
• PG&E trimmed back,vegetatlon uridergrowtti around substaborts to,remove-'potential
hiding'places,and
• At Metca0 specifically,PG&E Installed,temporary measures to shield equipment,
enhance,lighting and obstruct views into the,fadEity while more permanent measures are
being designed and engineered
Additional'physical,security measures PG&E is currently taking include,arridng other's:
• Opar ue'or said waft around the penneter to shield and otistnict vie+as of equipment
Inside the substation;
o Enhanced detection and deterrent systems',and
• Improved lighting'and camera systems.
PG&E has also%dbrked,wdhlaw enfarcement_and iidustry stakeholders fc share_information
and take appropriate actions on an ongoing basis to protect its facilities,
5uArnary Reporrtor Metcalf Incident Review 2
43
ALJ/GK1/lt2
Padfic Gas and Dectm Company
April 16,20 3.Sutnmary of Actions Takers
Foiiowiiig the April 2013 attack at ft Metcalf substation,PG&E began an,assessme itand
developed a three=year plan to'invest-more than$100 rrsilion to enhance securrty at its highest•
prionty-fa066s Some of the^adwris taker!by PG&E inpiuded-
Worked with local law onforcament,to increase security presence at Metcalf and
additional facilkies,(completed within 24 hours of the incafent),-
• Contracted'with a_private security c6rrparry to provide 24t7 security off m coverage
(completed within,24 hours of the incident);
• instalied,portabte,6ghting,(completed within,30 days of the incident),
• 1nstalled`temporery fencing,(completed within 30 days of the Incident);
• Contracted with security,consultants to conduct secu*,assessments(completed wt't6ln
30 days of the incident);
• Completed a series of tours of crrtic6substations whh law enforcement agencies:
Latitude and,longitude coordinates were Issued'to law,enforcement-aviation units,for,
aerial patrol whenevaliable'(June,201{3);
4t developed and distributed briefing"tailboards'to employees at rrei)ar substatfons to
discuss security procedures and suapbaous activity reporting'(July 2013};
• Received approved,permits and removed vegetation,surrounding Metcak(August 201;3);
• 1 nkiatdd an Internal training-program which included suspicious activity reporting and
awareness(September 2013),
• Mad€e imprdvements to the"Suspicious Activky R"eportfng'system incorporate Security
(October z013),
• Participated rn'an iridustryiand taw enforcdrfient sharing campaign in conluncti6h with
the Department of Homeland Security,the Federal,Energy-RegulatoryCommission,
North American EWrk Relfabikty,Corporation and the Federal Bateau of,InvestWtlon.
EvQnts,were held irr each-df the I0,Federal Erner - Management Agency
jurisdictions(November 2013);
Initiated an effort to fonpafize existing poiicies_and propedtires associated with the PG&E_
security,syiWm(March 2014),'
• Conducted anassessr"tent and best of cxirierit,se6urity systems at Metcalf(tularch 2014),
• Enhanced`camera surveiltance`at Metcalf(April 2014),
Summary Report,for,Metcalf ikide-i�tite+riew, 3
44
ALJ/GK1/it2 `
Pacific Gas and Electric Company
• Announced a$250,000 revard for informabon leading to the arrest and conviction of the
lhdiv ual(s)responsiOe for the attack on the anniversary of the incident(April 2014),
• Worked with local,lawenforoement to provide enhanced secunty'awareness on the`
anniversary of-the Metcalf event,{April 2014);
• Contracted with,security consultant to evatuate,and provide recommendations foi
processes and procedures at PG&E's security control center(June 2014),
• Invited Department of Homeland Security to perform a security assessment at Metcalf in
coordination wAth PG&E(June-2014);
• Released a'Job Bulletin'fdr additional operators at PG&E's security control center(July
2014),
• Performed on s►te post ordiir training.wcth se r►ty pe'rsorrsei at Metcalf(August,2014),
• Enhanced`perim6terligt4ing at craical,locatlons with additional,portable lighting at
Metcalf(September 2014);
Received permit and began construcd►on on a solid wall around Metcalf_(September
2014),
Pubilished,Ufility-Procedure,for Security Control Center Alarm Response(September
2014),
• Putrirshed Utility Procedure for Security Control Center Incident Response(September
2014),and
• Bnefed alarm and incident response protocols and trained security operators on revised
response protocols(September 2014),
There were a number_of other tn►ibatives that were in the process of being implemented as part
of PG&E's security pions when _Au4ust'26-27,2014,Metcalf burgtary'occurred
Summary Report for Rletcaif Inc-Fdent:Hevi w 4'
45
ALJ/GK1/lt2
Pacific Gas and Electnc Company
August 2414,Burglary at Metcalf Substation, Root Cause and Summary of Actions Taken
16cdent'Overview
Prior to,tfte August 2014 Metcati burglary;PG&E's action's to mingate,`sec unt"y threats,w o
rnair'tty focused on upgrading the physical security measures of the company's substations ak
part of an'overall;pIan to enhance security at substations
Batraean_the heu�g"of 22 10 on August 26,2014,and 02:41 on August`27,-2014 PG&E's
Metcalf facrAty.was-the site ai unauthorised entry.`As a resuk of the it truston,,approximately
538.6514f co'ristmiction toolsf and equ3prnent was,takon.
Despite detection by Moth the,third-party,video monitoring system arx!_ott_her security measures,
the thefts'were Trot iderrtrfied unUi 06 QO hours on August 27, 20t4;wrh ,eoristruction crevus
amiVed for w brk
60tist 26—27,2014,Summary of Actions Taken
lmnediately,following the August,2014 burglary,-PG&E took nurTibrous f6itial,actions to address
security gaps at the facility, cludli�g
Secured Metcalf Substation fend damaged during the burglarry(ca`mpleto wdhin 24
hours of;tha_inetden{),
• Gtieckedail equipmentwithin`Wbstationfor borationai,damage and found none
(completed within 24'hours of,the,incident):
•. Increased sedurity officer presence on sde'("leted within 24 hours of the incident),
• Enhanced portable,ligtiting onsito(completed wrthrn 48 hours of the.inciden t),
• Remrforced and citedredto ensure that roving patmis'w,ere'occumng wdhm Metcalf
Substation(completed-within 30 days'of the'lncident),
• Re4stabiished onsite roving;superilsorpositirin(completed wI(hIn 30,days of the_
Incident),
• Addressed alarm and-Incident response protocols for security" operstions,center
personnel(completed within 36 days-of the incident),
• Performed security revlew and penetration"Ing;at Metcalf substation(October 2014);;
• Enhanced camera systems at Metcalf(October 2014),,
• Re pinced,3rd,party guard cointractors_(Noverr"r 2014),and
• Replaced security operations contractors and increased staffing and supervision
(Nbvernbor 2014)_
54mmar}Report for Metcalf incident R&jew 5
46
ALJ/GK1/it2
Pacific Gas arrrl Electric Company
Root caul e_anatols flindinsts
PG&E also assembled'an experienced and mufti-discipiusary team from across the company to
conduct a root cause analysis of the August 2014 incident Th9 team's root cause analysis',
whidi is,submitted in a separate cohl'idential,document.found that the secairity`breach was due
to the.following,direct and root causes.
• Direct Cause, PG&E's security control center faded to,pr6ppc y respond to'alarms and
the on-site security officers failed to fellow clearly delineated post orders requiring them
to,perform continuous patrol of Metcalf Substation.
• Root Cause: Inedequate,training,and supervlslon,.created an environment in which
PG&E's Security Control Center personnel and on-site security officers is Red to follow
delineated procedures and pod orders
Additional,Actioni Planned cased on Root'Cause Analysis(Subset of Actions,Planned)
As a result affinding's°outlined in'ttfie root cause-analysis,PG&E is taking additional actions iri'a
timely�manner to prevent a similar incident from occurring Alf tonal acti0is include,among
other measures,
• Diiyelopkng and Implementing a robust tralning program for security officers to ensure
thafatarms are respondod to effnctivety
• irnplerrienting the uss of human performance toolswithiri securdycontrol center
operations,
• Developing a comprehensive,set of security policles,end procedures for'
a Security_guards.
,ca Work performed at°socu*control center,
o Training requirements and tracking process for security operators and officers;
and -
a Maintenance,and repairs for security systems
Conclusion
PG&E and the utility" industry have taken significant steps to increase security following the
Metcalf substation attack in April 2013 Although much work had been done to increase physical
security at facilities fotlowirig the incident,the subsequent burglary in August 2014 shoves that
training and supervision were inadequate taensure procedures were consistentiy follov►ed.
PG&E is cernmitted to addressing trakning`and supervision along with other issues,raisod by the
root cause analysis,while,contuiuing to work dosety with regulators and law enforcement to
maintain the security of the-company's faaftes
Summary Report for Aletcalf Incident Re�iery 6_
(End of Appendix B) 47
R 15-06-009 ALJ/GK1/jt2
Appendix C
(Assembly Bill 1650 adding Public Utilities Code Section 768.6
R 15-06-009 ALJ/GK1/lt2
Assembly Bill No. 1650
CHAPTER 472
An act to add Section 768 6 to the Public Utilities Code, relating to public
utilities
[Approved by Governor September 23, 2012 Filed with Secretary of State
September 23, 2012 ]
AB 1650, Portantino Public utilities emergency and disaster
preparedness
Under existing law, the Public Utilities Commission has regulatory
authority over public utilities, including electrical corporations and water
corporations, as defined
Existing law, the California Emergency Services Act, authorizes local
governments to create disaster councils by ordinance to develop plans for
meeting any condition constituting a local emergency or state of emergency,
as specified
This bill would require the commission to establish standards for disaster
and emergency preparedness plans within an existing proceeding, as
specified The bill would require an electrical corporation to develop, adopt,
and update an emergency and disaster preparedness plan, as specified The
bill would authorize every city, county, or city and county within the
electrical corporations service area to designate a point of contact for the
electrical corporation to consult with on emergency and disaster preparedness
plans The bill would require a water company regulated by the commission
to develop, adopt, and update an emergency and disaster preparedness plan,
as specified The bill would find and declare that county and city
participation in the preparation of electrical corporations' emergency and
R 15-06-009 ALJ/GK1/lt2
disaster preparedness plans is critical to a statewide emergency response
and, thus, is an issue of statewide concern.
The people of the State of California do enact as follows
SECTION 1 Section 768 6 is added to the Public Utilities Code, to read.
768 6 (a) The commission shall establish standards for disaster and
emergency preparedness plans within an existing proceeding, including,
but not limited to, use of weather reports to preposition manpower and
equipment before anticipated severe weather, methods of improving
communications between governmental agencies and the public, and methods
of working to control and mitigate an emergency or disaster and its
aftereffects The commission, when establishing standards pursuant to this
subdivision, may make requirements for small water corporations similar
to those imposed on class A water corporations under paragraph (2) of
subdivision (f)
(b) An electrical corporation, as defined in Section 218, providing service
in California shall develop, adopt, and update an emergency and disaster
preparedness plan in compliance with the standards established by the
commission pursuant to subdivision (a)
(1) (A) In developing and adopting an emergency and disaster
preparedness plan, an electrical corporation providing service in California
shall invite appropriate representatives of every city, county, or city and
county within that electrical corporation's service area in California to meet
with, and provide consultation to, the electrical corporation
(B) Every city, county, or city and county within the electrical
corporation's service area in California may designate a point of contact
for the electrical corporation to consult with on emergency and disaster
R 15-06-009 ALJ/GK1/jt2
preparedness plans
(C) The electrical corporation shall provide the point of contact designated
pursuant to subparagraph (B) with an opportunity to comment on draft
emergency and disaster preparedness plans
(2) For the purposes of best preparing an electrical corporation for future
emergencies or disasters, an emergency and disaster preparedness plan shall
address recent emergencies and disasters associated with the electrical
corporation or similarly situated corporations, and shall address remedial
actions for possible emergencies or disasters that may involve that
corporation's provision of service
(3) Every two years, in order to update and improve that electrical
corporation's emergency and disaster preparedness plan, an electrical
corporation providing service in California shall invite appropriate
representatives of every city, county, or city and county within that electrical
corporation's service area to meet with, and provide consultation to, the
electrical corporation
(4) For the purposes of best preparing an electrical corporation for future
emergencies or disasters, an electrical corporation updating its emergency
and disaster preparedness plan shall review the disasters and emergencies
that have affected similarly situated corporations since the adoption of the
plan, remedial actions taken during those emergencies or disasters, and
proposed changes to the plan The electrical corporation shall adopt in its
plan the changes that will best ensure the electrical corporation is reasonably
prepared to deal with a disaster or emergency
(c) A meeting pursuant to subdivision (b) shall be noticed and shall be
conducted in a public meeting that allows for the participation of appropriate
R 15-06-009 ALJ/GK1/lt2
representatives of counties and cities within the electrical corporation's
service area
(1) A county participating in a meeting pursuant to subdivision (b) may
inform each city within the county of the time and place of the meeting
(2) An electrical corporation holding a meeting pursuant to subdivision
(b) shall provide participating counties and cities with the opportunity to
provide written and verbal input regarding the corporations emergency and
disaster preparedness plan For purposes of this public meeting, an electrical
corporation may convene a closed meeting with representatives from every
city, county, or city and county within that electrical corporations service
area to discuss sensitive security-related information in the electrical
corporations emergency and disaster preparedness plan and to solicit
comment
(3) An electrical corporation shall notify the commission of the date,
time, and location of a meeting pursuant to subdivision (b)
(d) An electrical corporation shall conduct a meeting pursuant to
subdivision (b) no later than April 1, 2013, and every two years thereafter
(e) An electrical corporation shall memorialize a meeting pursuant to
subdivision (b), and shall submit its records of the meeting to the
commission
(f) (1) A water company regulated by the commission shall develop,
adopt, and update an emergency and disaster preparedness plan in
compliance with the standards established by the commission pursuant to
subdivision (a) This requirement shall be deemed fulfilled when the water
company files an emergency and disaster preparedness plan pursuant to
another state statutory requirement
R 15-06-009 ALJ/GK1/lt2
(2) A water company developing, adopting, or updating an emergency
and disaster preparedness plan pursuant to paragraph (1) shall hold meetings
with representatives from each city, county, or city and county in the water
company's service area regarding the emergency and disaster preparedness
plan
(g) An electrical corporation or a water corporation may fulfill a meeting
requirement imposed by this section by making a presentation regarding its
emergency and disaster preparedness plan at a regularly scheduled public
meeting of each disaster council created pursuant to Article 10 (commencing
with Section 8610) of Chapter 7 of Division 1 of Title 2 of the Government
Code within the corporations service area, or at a regularly scheduled public
meeting of the governing body of each city, county, or city and county
within the service area
SEC 2. The Legislature finds and declares that county and city
participation in the preparation of electrical corporations' emergency and
disaster preparedness plans is critical to a statewide emergency response
and, thus, is an issue of statewide concern and not a municipal affair, as that
term is used in Section 5 of Article XI of the California Constitution.
(End of Appendix C)
R 15-06-009 ALJ/GK1/lt2
Appendix D
(California Publicly Owned Electric Utilities)
R 15-06-009 ALJ/GK1/jt2
APPENDIX D
List of California Publicly Owned Electric Utilities
1 Alameda Municipal Power
PO BoxH
2000 Grand Street
Alameda CA 94501-0263
2 Anaheim, City of
Public Utilities Department
Anaheim City Hall West
201 South Anaheim Blvd , Suite 802
Anaheim CA 92805
3 Azusa Light and Water
P O Box 9500
729 North Azusa Avenue
Azusa CA 91702
4 Banning, City of
Electric Department
176 E Lincoln Street
P O Box 998
Banning CA 92220-0998
5 Biggs Municipal Utilities
P O Box 307
3016 Sixth Street
Biggs CA 95917
6 Burbank Water and Power
164 West Magnolia Boulevard
P O Box 631
Burbank CA 91503-0631
7 Cerritos, City of
Cerritos Electric Utility
P O Box 3130
Cerritos CA 90703
8 City and County of San Francisco
Power Enterprise of the
San Francisco Public Utilities Commission
1155 Market Street, 4th Floor
San Francisco CA 94103
R 15-06-009 ALJ/GK1/jt2
APPENDIX D
List of California Publicly Owned Electric Utilities
9 City of Industry
Administrative Offices
15625 East Stafford Street, Ste 100
City of Industry CA 91744
10 Colton Public Utilities
650 N La Cadena Dr
Colton Ca 92324-2823
11 Corona, City of
Department of Water and Power
755 Corporation Yard Way
Corona CA 92880
12 Eastside Power Authority
14181 Avenue 24
Delano CA 93215
13 Glendale Water and Power
141 N Glendale Ave, Level 4
Glendale CA 91206
14 Gridley Electric Utility
685 Kentucky Street
Gridley CA 95948
15 Healdsburg, City of
Electric Department
City Hall, 401 Grove Street
Healdsburg CA 95448-4723
16 Imperial Irrigation District
333 E Barioni Blvd
Imperial CA 92251
17 Kirkwood Meadows Public Utility District
PO BOX 247
Kirkwood CA 95646
18 Lathrop Irrigation District
c/o SSJID
PO BOX 747
Ripon, CA 95366
R 15-06-009 ALJ/GK1/jt2
APPENDIX D
List of California Publicly Owned Electric Utilities
19 Lassen Municipal Utility District
65 South Roop Street
Susanville CA 96130
20 Lodi Electric Utility
1331 South Ham Lane
Lodi CA 95242-3995
21 Lompoc, City of
P O Box 8001
City Hall, 100 Civic Center Plaza
Lompoc CA 93438-8001
22 Los Angeles Department of Water & Power
Box 51111
Los Angeles CA 90051-5700
23 Merced Irrigation District
P O Box 2288
744 West 20th Street
Merced CA 95340
24 Modesto Irrigation District
P O Box 4060
Modesto CA 95352-4060
25 Moreno Valley Electric Utility
14325 Frederick Street, Suite 9
Moreno Valley CA 92553
26 Needles, City of
Public Utility Authority
817 Third Street
Needles CA 92363-2933
27 Palo Alto, City of
Utilities Department
P O Box 10250
Palo Alto CA 94303
28 Pasadena Water and Power
150 South Los Robles Ave, Suite 200
Pasadena CA 91101-4613
r r
R 15-06-009 ALJ/GK1/jt2
APPENDIX D
List of California Publicly Owned Electric Utilities
29 Pittsburg, City of
Pittsburg Power Company d/b/a/ Island Energy
65 Civic Drive
Pittsburg CA 94565-3814
30 Port of Oakland
530 Water Street, Ste 3
Oakland CA 94607-3814
31 Port of Stockton
P O Box 2089
Stockton, CA 95201-2089
32 Power and Water Resources Pooling Authority
3514 West Lehman Road
Tracy CA 95304-9336
33 Rancho Cucamonga Municipal Utility
10500 Civic Center Drive
Rancho Cucamonga CA 91730
34 Redding Electric Utility
P O Box 496071
777 Cypress Avenue
Redding CA 96049-6071
35 Riverside, City of
Public Utilities Department
3750 University Avenue
Riverside CA 92501
36 Roseville Electric
311 Vernon Street
Roseville CA 95678
37 Sacramento Municipal Utility District
P O Box 15830
Sacramento CA 95852-1830
38 Shasta Lake, City of
P O Box 777
1650 Stanton Drive
Shasta Lake CA 96019-0777
R 15-06-009 ALJ/GK1/jt2
APPENDIX D
List of California Publicly Owned Electric Utilities
39 Shelter Cove Resort Improvement District
9126 Shelter Cove Road
Whitethorn CA 95589-9079
40 Silicon Valley Power
City of Santa Clara
1601 Civic Center Drive, Suite 202
Santa Clara, California 95050-4109
41 Trinity Public Utility District
P O Box 1216
Weaverville CA 96093
42 Truckee Donner Public Utilities District
P O Box 309
Truckee CA 96160
43 Turlock Irrigation District
P O Box 949
Turlock CA 95381-0949
44 Ukiah, City of
Electric Utilities Division
300 Seminary Avenue
Ukiah CA 95482-2680
45 Vernon, City of
Gas & Electric Department
4305 S Santa Fe Avenue
Vernon CA 90058-1714
46 Victorville Municipal Utilities Services
P O Box 5001
14343 Civic Drive
Victorville CA 92392-5001
(End of Appendix D)
R 15-06-009 ALJ/GK1/jt2
Appendix E
(List of Rural Electric Cooperatives)
R 15-06-009 ALJ/GK1/lt2
APPENDIX E
List of Rural Electric Cooperatives
1 Anza Electric Cooperative, Inc
P O Box 391909
58470 Highway 371
Anza CA 92539-1909
2 Plumas-Sierra Rural Electric Cooperative
73233 State Route 70, Suite A
Portola CA 96122-7069
3 Surprise Valley Electrification Corporation
516 US Hwy 395E
Alturas CA 96101-4228
4 Valley Electric Association, Inc
800 E Highway 372
Pahrump NV 89048-4624
(End of Appendix E)
R 15-06-009 ALJ/GK1/lt2
Appendix F
(Public Owned Utilities Representatives and Agents)
,
R 15-06-009 ALJ/GK1/lt2
APPENDIX F
Public Owned Utilities Representatives and Agents
1 California Municipal Utilities Association (CMUA)
915 L Street, Suite 1460
Sacramento, CA 95814
2 Northern California Power Authority (NCPA)
651 Commerce Drive
Roseville, CA 95678
3 Southern California Public Power Authority
225 South Lake Avenue, Suite 1250
Pasadena, CA 91101
(End of Appendix F)
R 15-06-009 ALJ/GK1/jt2
7
a
s�
Appendix G
(List of Facilities Based Communications Carriers
Authorized to Operate in California)
w
R 15-06-009 ALJ/GK1/jt2
APPENDIX G
List of Facilities-Based Communications Carriers
Authorized to Operate in California
Appendix G-1
Local Exchange Carriers
1 Pacific Bell
525 Market Street, Room 1944
San Francisco CA 94105
2 Verizon California, Inc
201 Spear Street, 7th Floor
San Francisco CA 94105
3 Calaveras Telephone Company
PO Box 37
Copperopolis CA 95228
4 Cal-Ore Telephone Company
PO Box 847
Dorris CA 96023
5 Ducor Telephone Company
PO Box 42230
Bakersfield CA 93384
6 Foresthill Telephone Company, Inc
811 S Madera
Kerman CA 93630
7 Happy Valley Telephone Co
PO Box 1004
Redmond OR 97756
8 Hornitos Telephone Company
PO Box 1004
Redmond OR 97756
9 Kerman Telephone Company
811 South Madera Avenue
Kerman CA 93630
10 Pinnacles Telephone Company
340 Live Oak Road
Paicines CA 95043
11 The Ponderosa Telephone Company
PO Box 21
O'Neals CA 93645
R 15-06-009 ALJ/GK1/jt2
z
Appendix G-1
Local Exchange Carriers
12 Surewest Telephone
PO Box 969
Roseville CA 95678
13 Sierra Telephone Company, Inc
PO Box 219
Oakhurst CA 93644
14 The Siskiyou Telephone Company
PO Box 157
Etna CA 96027
15 Volcano Telephone Company
PO Box 1070
Pine Grove CA 95665
16 Winterhaven Telephone Company
PO Box 1004
Redmond OR 97756
17 Centurytel of Eastern Oregon, Inc
6700 Via Austi Parkway
Las Vegas NV 89119
18 Citizens Telecommunications Co of Ca
9260 E Stockton Blvd
Elk Grove CA 95624
19 Frontier Communications of the Southwest Inc
9260 E Stockton Blvd
Elk Grove CA 95624
Appendix G-2
Competitive Local Carriers
1 Pacific Bell
525 Market Street, Room 1944
San Francisco CA 94105
2 Verizon California, Inc
201 Spear Street, 7th Floor
San Francisco CA 94105
3 Surewest Telephone
PO Box 969
Roseville CA 95678
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
Empire Unified Communications LLC
4 1 West Main St, Ste 650
Rochester NY 14614
5 AT&T Corp
525 Market Street, Room 1944
San Francisco CA 94105
6 Sprint Communications Company, LP
201 Mission Street, Suite 1500
San Francisco CA 94105
7 Fiber Data Systems
203 Bellefontaine Street
Pasadena CA 91105
8 Arrival Communications, Inc
515 S Flower Street, 47th Floor
Los Angeles CA 90071
9 MCI Metro Access Transmission Services
201 Spear Street, 7th Floor
San Francisco CA 94105
10 Pac-West Telecomm, Inc
6500 River Place Blvd Bldg 2, Suite 200
Austin TX 78730
11 CenturyLink Communications, LLC
6700 Via Austi Parkway
Las Vegas NV 89119
12 TW Telecom of California, LP
10475 Park Meadow Drive
Littleton CO 80124
13 Electric Lightwave, Inc
6160 Golden Hills Dr
Golden Valley MN 55416
14 IDT America Corp
520 Broad Street
Newark NJ 07102
15 Frontier Communications of America, Inc
9260 E Stockton Blvd
Elk Grove CA 95624
16 San Carlos Telecom Inc
2999 Oak Road, Suite 400
Walnut Creek CA 94597
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
17 Teleport Communications America, LLC
525 Market Street, Room 1944
San Francisco CA 94105
18 Verizon Select Services, Inc
One Verizon Way, VC53S455
Basking Ride NJ 07920
19 Preferred Long Distance, Inc
16830 Ventura Blvd , Suite 350
Encino CA 91436
20 Primus Telecommunications, Inc
7901 Jones Branch Dr , Ste 900
Mclean VA 22102
21 The Telephone Connection Local Svcs
8391 Beverly Blvd , Suite 350
Los Angeles CA 90045
22 Talk America, Inc
655 W Broadway, Ste 850
San Diego CA 92101
23 XO Communications Services
8851 Sandy Parkway
Sandy UT 84070
24 CCT Telecommunications, Inc
1106 E Turner Rd , Ste A
Lodi CA 95240
25 Integrated Telemanagement Services
4100 Guardian Street, Ste 110
Simi Valley CA 93063
26 North County Communications Corporation of California
3802 Rosecrans Street, Ste 485
San Diego CA 92110
27 Tcast Communications, Inc
25115 Avenue Stanford, B-210
Valencia CA 91355
28 Cox California Telcom, LLC
3732 Mt Diablo Blvd , Suite 358
Lafayette CA 94549
29 Global Crossing Local Services, Inc
225 Kenneth Drive
Rochester NY 14623
I s
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
30 Comcast Phone of California, LLC
3055 Comcast Place
Livermore CA 94551
31 McLeod USA Telecommunications Services, Inc
655 W Broadway, Ste 850
San Diego CA 92101
32 U S Telepacific Corp
515 S Flower, 47th Floor
Los Angeles CA 90071
33 Wholesale Airtime, Inc
27515 Enterprise Circle West
Temecula CA 92590
34 Utility Telephone, Inc
4202 Coronado Ave
Stockton CA 95204
35 TGEC Communications Co, LLC
6805 Tulunga Avenue
North Hollywood CA 91605
36 Mpower Communications Corp
515 S Flower Street, 47th Floor
Los Angeles CA 90071
37 Access Point, Inc
1100 Crescent Green Suite 109
Cary NC 27511
38 Globalinx Enterprises, Inc
275 Kenneth Drive
Rochester NY 14623
39 Quantumshift Communications, Inc
12657 Alcosta Blvd , Ste 418
San Ramon CA 94583
40 Level 3 Communications, LLC
225 Kenneth Drive
Rochester NY 14623
41 International Telcom, Ltd
417 Second Avenue West
Seattle WA 98119
42 Incontact, Inc
7730 S Union Park Ave , Ste 500
Midvale UT 84047
R.15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
43 Peak Communications, Inc
1442 East Lincoln Ave , Ste 479
Orange CA 92865
44 01 Communications, Inc
5190 Golden Foothill Parkway
El Dorado Hills CA 95762
45 Point To Point
PO Box 3148
Rancho Cordova CA 95741
46 Integra Telecom
6160 Golden Hills Dr
Golden Valley MN 55416
47 Southern California Edison
2244 Walnut Grove Ave
Rosemead CA 91770
48 Paetec Communications, Inc
655 W Broadway, Ste 850
San Diego CA 92101
49 Zayo Group, LLC
400 Centennial Parkway, Ste 200
Louisville CO 80027
50 Access One, Inc
820 W Jackson Blvd , 6th Floor
Chicago IL 60607
51 Navigator Telecommunications, LLC
PO Box 13860
North Little Rock AR 72113
52 Astound Broadband, LLC
401 Kirkland Parkplace, Suite 500
Kirkland WA 98033
53 Freedom Telecommunications, LLC
624 S Grand Avenue,Suite 1200
Los Angeles CA 90017
54 Earthlink Business, LLC
3000 Columbia House Blvd , Suite 106
Vancouver WA 98661
55 TNCI Operating Company, LLC
114 E Haley Street, Suite A
Santa Barbara CA 93101
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
56 Unity Telecom, LLC
2997 LBJ Freeway, Suite 225
Dallas TX 75234
57 Backbone Communications, Inc
811 Wilshire Blvd , Ste 1020
Los Angeles CA 90017
58 Surewest Televideo
PO Box 969
Roseville CA 95678
59 PNG Telecommunications, Inc
8805 Governors Hill Dr, Suite 250
Cincinnati OH 45249
60 Acn Communications Services, Inc
1000 Progress Place
Concord NC 28025
61 AT&T Corp
525 Market St, Room 1944
San Francisco CA 94105
62 Reliance Globalcom Services, Inc
114 Sansome Street, 11th Floor
San Francisco CA 94104
63 IP Networks, Inc
PO Box 192366
San Francisco CA 94119
64 Broadview Networks, Inc
1018 West 9th Ave
King Of Prussia PA 19406
65 Cbeyond Communications, LLC
320 Interstate North Pkwy SE
Atlanta Ga 30339
66 United States Telesis, Inc
200 N Westlake Blvd , Suite 104
Westlake Village CA 91362
67 Digital Net Phone, LLC
8391 Beverly Blvd , Suite 350
Los Angeles CA 90045
68 Comtech 21, LLC
1 Barnes Park South
Wallingford CT 06492
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
69 Onvoy, LLC
10300 6th Avenue N
Plymouth MN 55441
70 RGT Utilities of California, Inc
1221 Avenue Of The Americas, C2 Level
New York NY 10020
71 Metropolitan Telecomm of Calif, Inc
44 Wall Street, 14th Floor
New York NY 10005
72 Intrado Communications, Inc
1601 Dry Creek Drive
Longmont CO 80503
73 Sage Telecom Communications, LLC
10440 North Central Expressway, Suite 700
Dallas TX 75231
74 Telscape Communications, Inc
10440 North Central Expressway, Suite 700
Dallas TX 75231
75 Hypercube Telecom, LLC
3200 W Pleasant Run Road, Suite 300
Lancaster TX 75146
76 Call America, Inc
4202 Coronado Ave
Stockton CA 95204
77 Curatel, LLC
1605 West Olympic Blvd, Suite 701
Los Angeles CA 90015
78 Norcast Communications Corporation
1998 Santa Barbara Street, Suite 100
San Luis Obispo CA 93401
79 BCN Telecom, Inc
1200 Mt Kemble Ave , 3rd Floor
Harding Township NJ 07960
80 Wholesale Carrier Services, Inc
5471 N University Drive
Coral Springs FL 33067
81 NetFortis Acquisition Co, Inc
455 Market Street, Suite 620
San Francisco CA 94107
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
82 Great America Networks, Inc
10350 Heritage Park, Suite 101
Santa Fe Springs CA 90670
83 Budget Prepay, Inc
1325 Barksdale Blvd , Ste 200
Bossier City LA 71111
84 Enhanced Communications Network, Inc
1013 South Glendora Avenue
West Covina CA 91790
85 Creative Interconnect Communications
PO Box 656
San Carlos CA 94070
86 Global Telecom & Technology Americas, Inc
8484 Westpark Dr , Ste 720
Mclean VA 22102
87 McGraw Communications, Inc
3483 Satellite Blvd , Ste 202
Duluth GA 30096
88 Airespring, Inc
6060 Sepulveda Blvd , Suite 220
Van Nuys CA 91411
89 Bullseye Telecom, Inc
25925 Telegraph Road, Suite 210
Southfield MI 48033
90 Cypress Comms Operating Co , Inc
75 Erieview Plaza, Suite 400
Cleveland OH 44114
91 Calltower, Inc
10701 South River Front Parkway, No 450
South Jordan UT 84095
92 Cogent Communications of Calif, Inc
1015 31st Street, NW
Washington DC 20007
93 DMR Communications, Inc
PO Box 720128
Oklahoma City OK 73172
94 Telecom North America Inc
2654 W Horizon Ridge Pkwy ,, Ste 135-143
Henderson NV 89052
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
95 Teledata Solutions, Inc
200 N Westlake Blvd, Suite 104
Westlake Village CA 91362
96 Crown Castle NG West LLC
2000 Corporate Drive
Canonsburg PA 15317
97 A+ Wireless, Inc
PO Box 5454
Ventura CA 93005
98 Greenfield Communications, Inc
34112 Violet Lantern, Ste C
Dana Point CA 92629
99 Blue Casa Telephone, LLC
10 E Yanonali Street
Santa Barbara CA 93101
100 Easton Telecom Services, LLC
Summit Il, Unit A, 3046 Brecksville Rd
Richfield OH 44286
101 Think 12 Corporation
650 East Devon Avenue, Suite 133
Itasca IL 60143
102 DSCI Corporation
C/O CSI, 740 FL Central Parkway, Ste 2028
Lon ood FL 32750
103 First Communications, LLC
3340 West Market Street
Akron OH 44333
104 Granite Telecommunications, LLC
100 Newport Avenue Extension
Quincy MA 02171
105 Paxio, Inc
2045 Martin Avenue, Suite 204
Santa Clara CA 95050
106 Advanced Integrated Technologies, Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
107 Time Warner Cable Information Services (Calif)
60 Columbus Circle
New York NY 10023
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
108 TC Telephone, LLC
243 Washington
Red Bluff CA 96080
109 Neutral Tandem California, LLC
550 West Adams Street, Suite 900
Chicago IL 60661
110 Charter Fiberlink CA-CCO, LLC
12405 Powerscourt Drive
St Louis MO 63131
111 New Horizons Communications Corporation
420 Bedford St, Suite 250
Lexington MA 02420
112 Nexus Communications, Inc
740 FL Central Parkway, Ste 2028
Longwood FL 32750
113 Global Connect Telecommunications, Inc
1146 N Central Ave , No 297
Glendale CA 91202
114 Spectrotel, Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
115 Newpath Networks, LLC
2000 Corporate Drive
Canonsburg PA 15317
116 Ca-Clec LLC
2000 Corporate Drive
Canonsburg PA 15317
117 Champion Broadband California, LLC
380 Perry Street
Castle Rock CO 80104
118 Infotelecom, LLC
75 Erieview Plaza, Suite 400
Cleveland OH 44114
119 Bright House Networks Information Services (Calif ), LLC
4145 S Falkenburg Road, Suite 7
Riverview FL 33578
120 Extent Systems (California) LLC
3030 Warrenville Road, Suite 340
Lisle IL 60532
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
121 Mpower Networks Services, Inc
620-630 Third Street
San Francisco CA 94107
122 Ymax Communications Corporation
PO Box 6785
West Palm Beach FL 33405
123 Nextlink Wireless, Inc
13865 Sunrise Valley Drive
Herndon VA 20171
124 Sunesys, LLC
202 Titus Avenue
Warrington PA 18976
125 Cebridge Telecom Ca, LLC
520 Maryville Center Drive, Suite 300
St Louis MO 63141
126 Sonic Telecom, LLC
2260 Apollo Way
Santa Rosa CA 95407
127 MCC Telephony of the West, LLC
100 Crystal Run Road
Middletown NY 10941
128 Cal-Ore Communications, Inc
719 W Third Street
Dorris CA 96023
129 Bandwidth Com Clec, LLC
900 Main Campus Drive, Suite 500
Raleigh NC 27606
130 Affiniti, LLC
9208 Waterford Center Blvd
Austin TX 78758
131 Southern California Telephone Company
27515 Enterprise Circle West
Temecula CA 92590
132 Oacys Telecom, Inc
767 North Porter Road
Porterville CA 93257
133 Conterra Wireless Broadband LLC
2101 Rexford Road, Ste 200E
Charlotte NC 28211
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Appendix G-2
Competitive Local Carriers
134 Race Telecommunications, Inc
101 Haskins Way
So San Francisco CA 94080
135 Wide Voice, LLC
410 South Rampart, Suite 390
Las Vegas NV 89145
136 Channel Islands Telephone Company
3802 Rosecrans St, Ste 485
San Diego CA 92110
137 Rural Broadband Nowl LLC
111 South Main Street
Willits CA 95490
138 Telequality Communications, Inc
24715 Fairway Springs
San Antonio TX 78260
139 Telecommunication Systems, Inc
275 West St, Ste 400
Annapolis MD 21401
140 Telcentris Communications, LLC
9276 Scranton Road, No 300
San Diego CA 92121
141 Peerless Network of California, LLC
222 S Riverside Plaza, Suite 2730
Chicago IL 60606
142 Raw Bandwidth Telecom, Inc
PO Box 1305
San Bruno CA 94066
143 Birch Telecom of the West, Inc
2323 Grand Blvd , Suite 925
Kansas City KS 64108
144 Shasta County Telecom, Inc
3802 Rosccrans Street
San Diego CA 92110
145 Convergence Systems, Inc
10636 Scripps Summit Court, Suite 201
San Diego CA 92131
146 Empire Unified Communications LLC
1 West Main St, Ste 650
Rochester NY 14614
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
147 Public Wireless, Inc
25 East Trmble Road
San Jose CA 95131
148 Telco Experts, LLC
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
149 Cruzio Media, Inc
877 Cedar St, Ste 150
Santa Cruz CA 95060
150 Entelegent Solutions, Inc
3800 Arco Corporate Drive, Ste 310
Charlotte NC 28273
151 Mosaic Networx, LLC
454 Las Gallinas Ave, Suite 145
San Rafael CA 94903
152 Pacific Lightwave, a California Corporation
PO Box 10748
Palm Desert CA 92255
153 Calpop Com, Inc
600 West Seventh St, Ste 360
Los Angeles CA 90017
154 Broadvox-CLEC, LLC
75 Erieview Plaza, Suite 400
Cleveland OH 44114
155 Impulse Telecom, LLC
5383 Hollister Ave, Ste 240
Goleta CA 93111
156 Blue Rooster Telecom, Inc
PO Box 4959
San Luis Obispo CA 93403
157 Rosebud Telephone, LLC
Box 597
Rosebud TX 76570
158 Snowcrest Telephone, Inc
329 A N Mount Shasta Blvd , Suite 7
Mt Shasta CA 96067
159 Airus, Inc
840 South Canal, 7th Floor
Chicago IL 60607
R 15-06-009 ALJ/GK1/jt2
Appendix G-2
Competitive Local Carriers
160 Cenic Broadband Initiatives LLC
16700 Valley View Ave , Ste 400
La Mirada CA 90638
161 Comity Communications, LLC
3816 Ingersoll Avenue
Des Moines IA 50312
162 Crexendo Business Solutions, Inc
1615 South 52nd Street
Tempe AZ 85044
163 321 Communications, Inc
PO Box 15857
Brooksville FL 34604
164 Mobilitie, LLC
660 Newport Center Drive, Suite 200
Newport Beach CA 92660
165 Big River Telephone Company, LLC
24 S Minnesota Ave
Cape Girardeau MO 63703
166 Net Talk com, Inc
1100 NW 163rd Drive, Suite B-4
North Miami Beach FL 33169
167 XYN Communications of California, LLC
8275 S Eastern Ave , 200
Las Vegas NV 89123
168 Common Point, LLC
3243 Meadowbrook
Springfield IL 62711
169 Nobelbiz VOIP Services, Inc
5973 Avenida Encinas, Suite 202
Carlsbad CA 92008
170 Voxbeam Telecommunications, Inc
6314 Kingspointe Pkwy , Suite 1
Orlando FL 32819
171 CVIN, LLC
9479 North Fort Washington, Ste 105
Fresno CA 93730
172 Plumas-Sierra Telecommunications
73233 State Route 70, Suite A
Portola CA 96122
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Appendix G-2
Competitive Local Carriers
173 California Broadband Cooperative, Inc
1101 Nimitz Ave
Vallejo CA 94592
174 Blue Casa LLC
114 E Haley Street, Suite A
Santa Barbara CA 93101
175 dishNET Wireline L L C
9601 S Meridian Blvd
Englewood CO 80211
176 TQAvenger Telecom, LLC
12 Trophy Ridge
San Antonio TX 78258
177 Digital Transportation Corp
1720 Q Street
Sacramento CA 95811
178 Citrix Communications LLC
120018th Street N W, Suite 1200
Washington DC 20036
179 Optic Access
533 Airport Blvd , Suite 400
Burlingame CA 94111
180 Golden Bear Broadband LLC
P O Box 157
Etna CA 96027
181 Local Access Services LLC
11442 Lake Butler Blvd
Windermere FL 34786
182 Vodex Communications Corporation
3185 E2 Airway Avenue
Costa Mesa CA 92626
183 CallFire, Inc
1410 2nd Street, Floor 2
Santa Monica CA 90401
184 ATC Outdoor DAS, LLC
10 Presidential Way
Woburn Ma 01801
185 Ultimate Internet Access, Inc
3633 Inland Empire Blvd , Suite 890
Ontario CA 91764
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Appendix G-2
Competitive Local Carriers
186 LightSpeed Networks, Inc
921 SW Washington St, Suite 370
Portland OR 97205
Appendix G-3
Inter-Exchange Carriers
1 AT&T Corp
525 Market Street, Room 1944
San Francisco CA 94105
2 Global Crossing Telecommunications, Inc
225 Kenneth Drive
Rochester NY 14623
3 Sprint Communications Company, LP
201 Mission Street, Suite 1500
San Francisco CA 94105
4 Teleconnect Long Distance Svcs &Systems
201 Spear Street, 7th Floor
San Francisco CA 94105
5 Fiber Data Systems
203 Bellefontaine Street
Pasadena CA 91105
6 Intellicall Operator Services, Inc
1049 E Macedonia Church Road
Lee FL 32059
7 Coast International, Inc
14303 West 95th St
Lenexa KS 66215
8 Value Added Communications, Inc
12021 Sunset Hills Road, Suite 100
Reston VA 20190
9 Matrix Telecom, Inc
433 E Las Colinas Blvd , Suite 500
Irving TX 75039
10 Affinity Network Incorporated
250 Pilot Road, Ste 300
Las Vegas NV 89119
s
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Appendix G-3
Inter-Exchange Carriers
11 Working Assets Funding Service, Inc
101 Market Street, Suite 700
San Francisco CA 94105
12 Mitel Netsolutions, Inc
1146 N Alma School Rd
Mesa AZ 85201
13 Ameritel/Amerivision Comms Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
14 Arrival Communications, Inc
515 S Flower Street, 47th Floor
Los Angeles CA 90071
15 Nos Communications, Inc
250 Pilot Road, Ste 300
Las Vegas NV 89119
16 MCI Metro Access Transmission Services
201 Spear Street, 7th Floor
San Francisco CA 94105
17 Pac-West Telecomm, Inc
6500 River Place Blvd , Bldg 2, Suite 200
Austin TX 78730
18 Norstan Network Services, Inc
4805 Independence Parkway, Suite 101
Tama FL 33634
19 Roudebush Communications
176 W Logan Street, Suite 232
Noblesville IN 46060
20 Operator Service Company, LLC
6010 Exchange Parkway
San Antonio TX 78238
21 CenturyLink Communications, LLC
6700 Via Austi Parkway
Las Vegas NV 89119
22 National Comtel Network Inc
21031 Ventura Blvd , Ste 508
Woodland Hills CA 91364
23 Buehner-Fry, Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
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Appendix G-3
Inter-Exchange Carriers
24 TW Telecom of California, LP
10475 Park Meadow Drive
Littleton CO 80124
25 Business Discount Plan, Inc
1 World Trade Center, Suite 800
Long Beach CA 90831
26 Electric Lightwave Inc
6160 Golden Hills Dr
Golden Valley MN 55416
27 MCI Communications Services, Inc
201 Spear Street, 7th Floor
San Francisco CA 94105
28 Dialink Corporation
1660 S Amphlett Blvd , Ste 314
San Mateo CA 94402
29 Cincinnati Bell Any Distance, Inc
201 East Fourth Street, 103-1280
Cincinnati OH 45201
30 TTI National, Inc
201 Spear Street, 7th Floor
San Francisco CA 94105
31 Covista, Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
32 IDT America Corp
520 Broad Street
Newark NJ 07102
33 Frontier Communications of America, Inc
PO Box 340
Elk Grove CA 95759
34 Nosva, Limited Partnership
250 Pilot Road, Ste 300
Las Vegas NV 89119
35 San Carlos Telecom Inc
2999 Oak Road, Suite 400
Walnut Creek CA 94597
36 Teleport Communications America, LLC
525 Market Street, Room 1944
San Francisco CA 94105
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Appendix G-3
Inter-Exchange Carriers
37 Communications Brokers & Consultants
23939 Ventura Blvd
Calabasas CA 91302
38 California RSA No 3 Limited Ptnshp
PO Box 2607
Oakhurst CA 93644
39 Smart City Networks, LP
28 W Grand Ave
Montvale NJ 07645
40 Cybernet Communications Inc
7750 Gloria Ave
Van Nuys CA 91406
41 Bulletins, Inc
39252 Winchester Rd , No 107-259
Murrieta GA 92563
42 Verizon Select Services, Inc
One Verizon Way, VC535455
Basking Ride NJ 07920
43 LDC Telecommunications Inc
2451 McMullen Booth Rd , Ste 200
Clearwater FL 33759
44 Tremcom International
6167 Bristol Pkwy , 320
Culver City CA 90230
45 Preferred Long Distance, Inc
16830 Ventura Blvd , Suite 350
Encino CA 91436
46 Primus Telecommunications, Inc
7901 Jones Branch Dr, Ste 900
Mclean VA 22102
47 Worldnet Communications Services, Inc
80 Wood Rd , Suite 308
Camarillo CA 93010
48 The Telephone Connection Local Svcs
8391 Beverly Blvd , Suite 350
Los Angeles CA 90045
49 Broadwing Communications, LLC
225 Kenneth Drive
Rochester NY 14623
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Appendix G-3
Inter-Exchange Carriers
50 CTC Communications Corp
225 Cedar Hill Street, Suite 111
Marlborough MA 01752
51 Talk America, Inc
655 W Broadway, Ste 850
San Diego CA 92101
52 XO Communications Services
8851 Sandy Parkway
Sandy UT 84070
53 Business Telecom, LLC d/b/a EarthLink Business
2610 Horizon Drive SE, Ste B
Grand Rapids MI 49546
54 Network Enhanced Technologies, Inc
700 South Flower Street, Suite 420
Los Angeles CA 90017
55 CCT Telecommunications, Inc
1106 E Turner Road, Ste A
Lodi CA 95240
56 Integrated Telemanagement Services
4100 Guardian Street, Ste 110
Simi Valley CA 93063
57 ABS-CBN Telecom North America, Inc
150 Shoreline Drive
Redwood City CA 94065
58 North County Communications Corporation of California
3802 Rosecrans, Ste 485
San Diego CA 92110
59 Tcast Communications, Inc
25115 Avenue Stanford
Valencia CA 91355
60 Sierra Telephone Long Distance
PO Box 1505
Oakhurst CA 93644
61 Telecom House Inc (Sterling)
8421 Wilshire Blvd , Ste 300
Beverly Hills CA 90211
62 Global Tel*Link Corporation
12021 Sunset Hills Road, Suite 100
Reston VA 20190
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Appendix G-3
Inter-Exchange Carriers
63 Cox California Telcom, LLC
3732 Mt Diablo Blvd , Suite 358
Lafayette CA 94549
64 Global Crossing Local Services, Inc
225 Kenneth Drive
Rochester NY 14623
65 Comcast Phone of California, LLC
3055 Comcast Place
Livermore CA 94551
66 BT Americas, Inc
11440 Commerce Park Drive, Ste 1000
Reston VA 20191
67 McLeod USA Telecommunications Services, Inc
655 W Broadway, Ste 850
San Diego CA 92101
68 U S Telepacific Corp
515 S Flower, 47th Floor
Los Angeles CA 90071
69 Verizon Long Distance LLC
One Verizon Way, VC53S460
Basking Ride NJ 07920
70 Dial Long Distance, Inc
762 West Ventura Boulevard
Camarillo CA 93010
71 Wholesale Airtime, Inc
27515 Enterprise Circle West
Temecula CA 92590
72 DeltaCom, LLC
7037 Old Madison Pike, Suite 400
Huntsville AL 35802
73 Custom Network Solutions, Inc
210 Route 4 East, Suite 201
Paramus NJ 07652
74 Legacy Long Distance International, Inc
10833 Valley View Street, Ste 150
Cypress CA 90630
75 Association Administrators, Inc
180 East Main Street, Ste 203
Smithtown NY 11787
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Appendix G-3
Inter-Exchange Carriers
76 Associated Network Partners, Inc
3243 Meadowbrook
Springfield IL 62711
77 SBC Long Distance, LLC
525 Market St, Room 1944
San Francisco CA 94105
78 Utility Telephone, Inc
4202 Coronado Ave
Stockton CA 95204
79 TGEC Communications Co , LLC
6805 Tulunga Avenue
North Hollywood CA 91605
80 Volcano Long Distance
PO Box 1070
Pine Grove CA 95665
81 Surewest Long Distance
PO Box 969
Roseville CA 95678
82 Net One International, Inc
457 South Avalon Park Blvd , Suite 500
Orlando FL 32828
83 Ldmi Telecommunications, Inc
655 W Broadway, Ste 850
San Diego CA 92101
84 Mpower Communications Corp
515 S Flower Street, 47th Floor
Los Angeles CA 90071
85 Locus Telecommunications, Inc
2200 Fletcher Ave , 6th Floor
Fort Lee NJ 07204
86 Access Point, Inc
1100 Crescent Green, Ste 109
Cary NC 27511
87 Americatel Corporation
433 E Las Colinas Blvd , Suite 500
Irving TX 75039
88 U S Telecom Long Distance, Inc
3960 Howard Hughes Prkwy ,, Suite 5001F
Las Vegas NV 89109
R 15-06-009 ALJ/GK1/j t2
Appendix G-3
Inter-Exchange Carriers
89 Globalinx Enterprises, Inc
275 Kenneth Drive
Rochester NY 14623
90 Quantumshift Communications, Inc
12657 Alcosta Blvd , Suite 418
San Ramon CA 94583
91 Level 3 Communications, LLC
225 Kenneth Drive
Rochester NY 14623
92 NTT America, Inc
757 Third Avenue, Floor 14
New York NY 10017
93 Infotech Telecomms and Network Inc
725 Evans Road
San Luis Obisbo CA 93401
94 Airnex Communications, Inc
3075 Breckinridge Blvd , Suite 425
Duluth GA 30096
95 International Telcom, Ltd
417 Second Avenue West
Seattle WA 98119
96 Network Operator Services, Inc
P O Box 3529
Longview TX 75606
97 Incontact, Inc
7730 S Union Park Ave, Ste 500
Midvale UT 84047
98 Kddi America, Inc
825 Third Avenue, 3rd Floor
New York NY 10022
99 American Phone Services, Corp
308 Maxwell Rd, Suite 100
Alpharetta GA 30004
100 Pacific Centrex Services, Inc
6805 Tulunga Avenue
North Hollywood CA 91605
101 Peak Communications, Inc
1442 East Lincoln Avenue, No 479
Orange CA 92865
R 15-06-009 ALJ/GK1/jt2
Appendix G-3
Inter-Exchange Carriers
102 Custom Teleconnect, Inc
2600 Maitland Center Pky ,, Suite 300
Maitland FL 32751
103 CenturyLink Public Communications, Inc
6700 Via Austi Parkway
Las Vegas NV 89119
104 Clear World Communications Corp
2901 W MacArthur Blvd , Suite 204
Santa Ana CA 92704
105 01 Communications, Inc
5190 Golden Foothill Parkway
El Dorado Hills CA 95762
106 Point To Point, Inc
PO Box 3148
Rancho Cordova CA 95741
107 Advanced Telcom, Inc
6160 Golden Hills Dr
Golden Valley MN 55416
108 Southern California Edison
2244 Walnut Grove Ave
Rosemead CA 91770
109 Paetec Communications, Inc
655 W Broadway, Ste 850
San Diego CA 92101
110 Zayo Group, LLC
400 Centennial Parkway, Suite 200
Louisville CO 80027
111 Wnitel Communications, LLC
225 Kenneth Drive
Rochester NY 14623
112 Advantage Telecommunications Corp
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
113 Astound Broadband, LLC
401 Kirkland Parkplace, Suite 500
Kirkland WA 98033
114 Freedom Telecommunications, LLC
624 S Grand Avenue, Suite 1200
Los Angeles CA 90017
R 15-06-009 ALJ/GK1/jt2
Appendix G-3
Inter-Exchange Carriers
115 Earthlink Business, LLC
3000 Columbia House Blvd , Suite 106
Vancouver WA 98661
116 Unity Telecom, LLC
2997 LBJ Freeway, Suite 225
Dallas TX 75234
117 Openpop Com, Inc
3055 Wilshire Blvd , Suite 730
Los Angeles CA 90010
118 Backbone Communications, Inc
811 Wilshire Blvd , Ste 1020
Los Angeles CA 90017
119 Surewest Televideo
PO Box 969
Roseville CA 95678
120 Network IP, LLC
1807 Judson Road
Longview TX 75605
121 PNG Telecommunications, Inc
8805 Governors Hill Dr, Suite 250
Cincinnati OH 45249
122 AT&T Corp
525 Market St, Room 1944
San Francisco CA 94105
123 Reliance Globalcomm Services, Inc
114 Sansome Street, 11th Floor
San Francisco CA 94104
124 IP Networks, Inc
PO Box 192366
San Francisco CA 94119
125 Broadview Networks, Inc
1018 West 9th Ave
King Of Prussia PA 19406
126 Telmex USA, LLC
3350 SW 148 Avenue, Suite 400
Miramar FL 33027
127 ANPI Business, LLC
7460 Warren Parkway, Ste 218
Frisco TX 75034
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Appendix G-3
Inter-Exchange Carriers
128 Cbeyond Communications, LLC
320 Interstate North Pkwy SE
Atlanta GA 30339
129 Digital Net Phone, LLC
8391 Beverly Blvd , Suite 350
Los Angeles CA 90045
130 Encompass Communications, LLC
119 West Tyler Street, Suite 260
Longview TX 75601
131 Onvoy, LLC
10300 6th Avenue N
Plymouth MN 55441
132 RGT Utilities of California, Inc
1221 Avenue Of The Americas, C2 Level
New York NY 10020
133 Aries Network, Inc
5973 Avenida Encinas, Suite 202
Carlsbad CA 92008
134 Intrado Communications, Inc
1601 Dry Creek Drive
Longmont CO 80503
135 Sage Telecom Communications, LLC
10440 North Central Expressway, Suite 700
Dallas TX 75231
136 Telscape Communications, Inc
10440 North Central Expressway, Suite 700
Dallas TX 75231
137 Call America, Inc
4202 Coronado Ave
Stockton CA 95204
138 Curatel, LLC
1605 West Olympic Blvd , Suite 701
Los Angeles CA 90015
139 Norcast Communications Corporation
1998 Santa Barbara Street, Suite 100
San Luis Obispo CA 93401
140 Wholesale Carrier Services, Inc
5471 N University Drive
Coral Springs FL 33067
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Appendix G-3
Inter-Exchange Carriers
141 NetFortis Acquisition Co , Inc
455 Market Street, Suite 620
San Francisco CA 94107
142 Great America Networks, Inc
10350 Heritage Park, Suite 101
Santa Fe Springs CA 90670
143 Budget Prepay, Inc
1325 Barksdale Blvd , Ste 200
Bossier City LA 71111
144 Creative Interconnect Communications
PO Box 656
San Carlos CA 94070
145 Onelink Communications, Inc
8400 N University Drive, Suite 204
Tamarac FL 33321
146 New World Telecom International, Inc
2711 Centerville Road, Suite 400
Wilmington DE 19808
147 McGraw Communications, Inc
3483 Satellite Blvd , Ste 202
Duluth GA 30096
148 Cypress Comms Operating Co, Inc
75 Erieview Plaza, Suite 400
Cleveland OH 44114
149 Calltower, Inc
10701 South River Front Parkway, No 450
South Jordan UT 84095
150 Cogent Communications of Calif, Inc
1015 31st Street, NW
Washington DC 20007
151 DMR Communications, Inc
PO Box 720128
Oklahoma City OK 73172
152 Telecom North America Inc
2654 W Horizon Ridge Pkwy ,, Ste 135-143
Henderson NV 89052
153 Broadband Dynamics, LLC
8757 E Via De Commercio
Scottsdale AZ 85258
R 15-06-009 ALJ/GK1/jt2
Appendix G-3
Inter-Exchange Carriers
154 Crown Castle NG West LLC
2000 Corporate Drive
Canonsburg PA 15317
155 A+ Wireless, Inc
PO Box 5454
Ventura CA 93005
156 Blue Casa Telephone, LLC
10 E Yanonali Street
Santa Barbara CA 93101
157 Chunghwa Telecom Global, Inc
2107 N First St, Ste 580
San Jose CA 95131
158 Independent Telecommunications Systems,
4079 Park East Court
Kentwood MI 49546
159 Granite Telecommunications, LLC
100 Newport Avenue Extension
Quincy MA 02171
160 Paxio, Inc
2045 Martin Avenue, Suite 204
Santa Clara CA 95050
161 Advanced Integrated Technologies, Inc
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
162 Time Warner Cable Information Services
60 Columbus Circle
New York NY 10023
163 TC Telephone, LLC
243 Washington
Red Bluff CA 96080
164 Neutral Tandem California, LLC
550 West Adams Street, Suite 900
Chicago IL 60661
165 Charter Fiberlink CA-CCO, LLC
12405 Powerscourt Drive
St Louis MO 63131
166 Lucky Communications, Inc
1028 Mission Street
San Francisco CA 94103
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Appendix G-3
Inter-Exchange Carriers
167 Globalphone Corporation
137 North Washington Street, Suite 200
Falls Church VA 22046
168 Worldwide Telecommunications, Inc
4505 Las Virgenes Road, Suite 115
Calabasas CA 91302
169 Global Connect Telecommunications, Inc
1146 N Central Ave , No 297
Glendale CA 91202
170 Newpath Networks, LLC
2000 Corporate Drive
Canonsburg PA 15317
171 Ca-Clec LLC
2000 Corporate Drive
Canonsburg PA 15317
172 Champion Broadband California, LLC
380 Perry Street
Castle Rock CO 80104
173 Infotelecom, LLC
75 Erieview Plaza, Suite 400
Cleveland OH 44114
174 Bright House Networks Information Services (Calif), LLC
4145 S Falkenburg Road, Suite 7
Riverview FL 33578
175 Extenet Systems (California) LLC
3030 Warrenville Road, Suite 340
Lisle IL 60532
176 IBFA Acquisition Company, LLC
C/O CSI, 740 FL Central Parkway, Ste 2028
Longwood FL 32750
177 800 Response Information Services, LLC
1795 Williston Road, Suite 200
South Burlington VT 05403
178 Mpower Networks Services, Inc
620-630 Third Street
San Francisco CA 94107
179 Nextlink Wireless, Inc
13865 Sunrise Valley Drive
Herndon VA 20171
r
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Appendix G-3
Inter-Exchange Carriers
180 Sunesys, LLC
202 Titus Avenue
Warrington PA 18976
181 Cebridge Telecom Ca, LLC
520 Maryville Center Drive, Suite 300
St Louis MO 63141
182 Sonic Telecom, LLC
2260 Apollo Way
Santa Rosa CA 94507
183 Smart Choice Communications, LLC
PO Box 720128
Oklahoma City OK 73172
184 MCC Telephony of the West, LLC
100 Crystal Run Road
Middletown NY 10941
185 BLC Management LLC
6905 N Wickham Road, Suite 403
Melbourne FL 32940
186 Alliance Group Services, Inc
1221 Post Road East
Westport CT 06880
187 Bandwidth Com Clec, LLC
900 Main Campus Drive, Suite 500
Raleigh NC 27606
188 Oacys Telecom, Inc
767 North Porter Road
Porterville CA 93257
189 Channel Islands Telephone Company
3802 Rosecrans St, Ste 485
San Diego CA 92110
Telequality Communications, Inc
190 24715 Fairway Springs
San Antonio TX 78260
191 CapTex Telecom, LLC
119 West Tyler Street, Ste 100
Longview TX 75601
192 Telcentris Communications, LLC
9276 Scranton Road, No 300
San Diego CA 92121
R 15-06-009 ALJ/GK1/jt2
Appendix G-3
Inter-Exchange Carriers
193 Roadway Communications, Inc
16012 S Western Avenue, Suite 303
Gardena CA 90247
194 Ekit Com Inc
27 Drydock Ave , 5th Floor
Boston MA 02210
195 Call One Inc
225 W Wacker Drive, 8th Floor
Chicago IL 60606
196 Momentum Telecom, Inc
880 Montclair Road, Suite 400
Birmingham AL 35213
197 Peerless Network of California, LLC
222 S Riverside Plaza, Suite 2730
Chicago IL 60606
198 Shasta County Telecom, Inc
3802 Rosccrans Street
San Diego CA 92110
199 Convergence Systems, Inc
10636 Scripps Summit Court, Suite 201
San Diego CA 92131
200 Callcatchers, Inc
169 Saxony Rd , Ste 206
Encinitas CA 92024
201 Public Wireless, Inc
25 East Trimble Road
San Jose CA 95131
202 X2 Telecom, LLC
PO Box 90346
Santa Barbara CA 93190
203 Cruzio Media, Inc
877 Cedar St, Ste 150
Santa Cruz CA 95060
204 Mosaic Networx, LLC
454 Las Gallinas Ave , Suite 145
San Rafael CA 94903
205 Broadvox-CLEC, LLC
75 Erieview Plaza, Suite 400
Cleveland OH 44114
f
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Appendix G-3
Inter-Exchange Carriers
206 Impulse Telecom, LLC
5383 Hollister Ave , Ste 240
Goleta CA 93111
207 Telus Communications Company
500 8th Street, NW
Washington DC 20004
208 Frontier Communications Online & LD
9260 E Stockton Blvd
Elk Grove CA 95624
209 Blue Rooster Telecom, Inc
PO Box 4959
San Luis Obispo CA 93403
210 Rosebud Telephone, LLC
PO Box 597
Rosebud TX 76570
211 Pay Tel Communications, Inc
PO Box8179
Greensboro NC 27419
212 Airus, Inc
840 South Canal, 7th Floor
Chicago IL 60607
213 Cenic Broadband Initiatives LLC
1415 L Street, Suite 870
Sacramento CA 95814
214 Comity Communications, LLC
3816 Ingersoll Avenue
Des Moines IA 50312
215 Digital West Networks, Inc
3620 Sacramento Drive, Suite 102
San Luis Obispo CA 93401
216 Splice Communications, Inc
1900 S Norfolk St, Suite 350
San Mateo CA 94403
217 Bestel (USA), Inc
2323 Bryan Street, Suite 2040
Dallas TX 78205
218 Crexendo Business Solutions, Inc
1615 South 52nd Street
Tempe AZ 85281
h
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Appendix G-3
Inter-Exchange Carriers
219 Mobilitie, LLC
660 Newport Center Drive, Suite 200
Newport Beach CA 92660
220 Big River Telephone Company, LLC
24 S Minnesota Ave
Cape Girardeau MO 63703
221 XYN Communications of California, LLC
8275 S Eastern Ave, 200
Las Vegas NV 89123
222 Common Point, LLC
3243 Meadowbrook
Springfield IL 62711 -
223 Voxbeam Telecommunications, Inc
6314 Kingspointe Pkwy ,, Suite 1
Orlando FL 32819
224 Plumas Sierra Telecommunications
73233 State Route 70, Suite A
Portola CA 96122
225 California Broadband Cooperative, Inc
1101 Nimitz Ave
Vallejo CA 94592
226 Masergy Communications, Inc
2740 North Dallas Parkway
Plano TX 75093
227 Lit San Leandro, LLC
777 Davis Street
San Leandro CA 94577
228 IFN com, Inc
9841 Airport Blvd , 9th Floor
Los Angeles CA 90045
229 LCB Communications, LLC
P O Box 1246
Sam Martin CA 95020
230 Telecircuit Network Corporation
1725 Winward Concourse,Suite 150
Alpharetta GA 30005
231 Optic Access
533 Airport Blvd , Suite 400
Burlingame CA 94111
R 15-06-009 ALJ/GK1/jt2
Appendix G-3
Inter-Exchange Carriers
232 Metro Star Networks, Inc
145 S Halcyon Rd , Suite E
Arroyo Grande CA 93420
233 Local Access Services LLC
11442 Lake Butler Blvd
Windermere FL 34786
234 Public Interest Telecom of CA
1050 Heinz Ave
Berkeley CA 94710
235 Vodex Communications Corporation
3185 E2 Airway Avenue
Costa Mesa CA 92626
236 Transbeam, Inc
8 West 38th St, 7th Floor
New York City NY 10018
237 Global Telco Group Inc
1420 Spring Hill Road, Suite 401
Mclean VA 22102
238 Sage Communications, Inc
4274 Enfield Court, Suite 1600
Palm Harbor FL 34685
239 CallFire, Inc
1410 2nd Street, Floor 2
Santa Monica CA 90401
240 Smart Card Services, Inc
15953 NW 16th Street
Pembroke Pines FL 33028
241 Surfnet Communications, Inc
25600 Hillside Road
Los Gatos CA 95033
242 Viasat Inc
349 Inverness Drive South
Englewood CO 80112
243 Ultimate Internet Access, Inc
3633 Inland Empire Blvd , Suite 890
Ontario CA 91764
O y
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Appendix G-3
Inter-Exchange Carriers
244 LightSpeed Networks, Inc
921 SW Washington St, Suite 370
Portland OR 97205
Appendix G4
Commercial Mobile Radio Service Providers (Cellular Carriers)
1 Cellco Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
2 GTE Mobilnet of CA , Ltd Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
3 Los Angeles SMSA Limited Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
4 Sacramento Valley Ltd Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
5 Fresno MSA Ltd Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
6 GTE Mobilnet of Santa Barbara
201 Spear Street, 7th Floor
San Francisco CA 94105
7 Santa Barbara Cellular Systems, Ltd
1525 Market St, Room 1944
San Francisco CA 94105
8 AT&T Mobility Wireless Operations Holdings Inc
525 Market St
San Francisco CA 94105
9 WWC License, LLC
180 Washington Valley Road
Bedminster NJ 07921
10 California RSA No 3 Ltd Partnership
PO Box 2607
Oakhurst CA 93644
R 15-06-009 ALJ/GK1/jt2
Appendix G4
Commercial Mobile Radio Service Providers (Cellular Carriers)
11 Verizon Wireless, LLC
201 Spear Street, 7th Floor
San Francisco CA 94105
12 Modoc RSA Limited Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
13 California RSA No 4 Ltd Partnership
201 Spear Street, 7th Floor
San Francisco CA 94105
14 United States Cellular Corporation
8410 West Bryn Mawr
Chicago IL 60631
15 T-Mobile West LLC
1755 Creekside Oasks Dr , STE 190
Sacramento CA 95833
16 New Cingular Wireless PCS, LLC
525 Market St, Room 1944
San Francisco CA 94105
17 Cricket Communications, Inc
525 Market St, Room 1944
San Francisco CA 94105
18 Metropcs California, LLC
1755 Creekside Oasks Dr, Ste 190
Sacramento CA 95833
19 Accessible Wireless, LLC
100 Via Dela Valle, Suite 200
Del Mar CA 92014
20 California Valley Broadband, LLC
1015 - B Airport Road
Rio Vista CA 94571
t �
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Appendix G-5
Radio Telephone Utilities
1 Madera Radio Dispatch
PO Box 28
Madera CA 93639-0028
2 Fresno Mobile Radio Inc
160 North Broadway
Fresno CA 93701
3 American Messaging Services, LLC
1720 Lakepointe Dr, Ste 100
Lewisville TX 75057
4 Velocita Wireless
70 Wood Avenue South, 3rd Floor
Iselin NJ 08830
5 USA Mobility Wireless, Inc
6850 Versar Center, Suite 420 - Tax Dept
Springfield VA 22151
6 Telefonica USA, Inc
1111 Brickell Avenue, 10thFloor
Miami FL 33131
(End of Appendix G)
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Appendix H
(Service List of Resolution No W-4823)
R 15-06-009 ALJ/GK1/jt2
Service List of Resolution No W-4823
Edward Jackson
Park Water Company
P O Box 7002
DOWNEY CA 90241-7002
Leigh K. Jordan
Apple Valley Ranchos Wtr Co
P O Box 7002
DOWNEY CA 90241
Lawrence Morales
East Pasadena Water Co
3725 East Mountain View Ave.
PASADENA CA 91107
Robert J DiPrimio
Valencia Water Co
24631 Avenue Rockefeller
VALENCIA CA 91335
Robert L Kelly
Suburban Water Systems
1211 E Center Court Drive
COVINA CA 91724-3603
Daniel A Dell'Osa
San Gabriel Valley Water Co
P O Box 6010
EL MONTE CA 91734
Michael Whitehead
San Gabriel Valley Water Co
P O. Box 6010
EL MONTE CA 91734
Timothy J Ryan, Gen Counsel
San Gabriel Valley Water Co
P O Box 6010
EL MONTE CA 91734
R 15-06-009 ALJ/GK1/jt2
Keith Switzer
Golden State Water Company
630 East Foothill Blvd
SAN DIMAS CA 91773-9016
Robert Thomas Adcock
Alco Water Service
249 Williams Road
SALINAS CA 93905
Martin A Mattes
California Water Association
50 California Street
SAN FRANCISCO CA 94111
Francis S Ferraro
California Water Service Co
1720 N. First Street
SAN JOSE CA 95112-4598
John Roeder
Great Oaks Water Company
P O Box 23490
SAN JOSE CA 95153-3490
Palle Jensen
San Jose Water Company
374 W Santa Clara Street
SAN JOSE CA 95196-0001
Robert C Cook, Sr
Frurtridge Vista Water Company
1108 Second Street, Suite 204
SACRAMENTO CA 95814
David P Stephenson
California-American Water Co
4701 Beloit Drive
SACRAMENTO CA 95838
R 15-06-009 ALJ/GK1/jt2
Robert S Fortino
Del Oro Water Company, Inc
Drawer 5172
CHICO CA 95927
John Garon
Golden State Water Company
630 East Foothill Blvd
SAN DIMAS CA 91773-9016
Gladys Rosendo
Golden State Water Company
630 East Foothill Blvd
SAN DIMAS CA 91773-9016
John K. Hawks
California Water Association
Mail Code E3-608
601 Van Ness Ave , 2047
SAN FRANCISCO CA 94102 -
E Garth Black
Cooper, White, & Cooper, LLP
201 California Street, 17th Street
SAN FRANCISCO CA 94111
Sarah Leeper
Attorney at Law
Manatt, Phelps & Phillips, LLP
One Embarcadero Ctr ,, 30th Floor
SAN FRANCISCO A 94111
Jose E Guzman, Jr
California Water Association
50 California Street
SAN FRANCISCO CA 94111
Joseph M Karp
Winston & Strawn, LLP
101 California St , 39th Floor
SAN FRANCISCO CA 94111
Ts =s
R 15-06-009 ALJ/GK1/jt2
Thomas Smegal
California Water Service Company
1720 North First
SAN JOSE CA 95112
Edward Howard
CPUC —Policy & Planning Div
505 Van Ness Avenue, Rm 5119
SAN FRANCISCO CA 94102
Jacquline A. Reed
CPUC —ALJ
505 Van Ness Avenue, Rm 5017
SAN FRANCISCO CA 94102
Jason J Zeller
CPUC-Legal Division, Rm 5105
505 Van Ness Avenue
SAN FRANCISCO CA 94102
Joe Como
CPUC — DRA- Admin Branch
505 Van Ness Avenue, Rm 4101
SAN FRANCISCO CA 94102
Ravi Kumra
CPUC — DWA
505 Van Ness Avenue
SAN FRANCISCO CA 94102
Ting-Pong Yuen
CPUC — ORA 3-D
505 Van Ness Avenue
SAN FRANCISCO CA 94102
Yoke W Chan
CPUC —ORA 3-D
505 Van Ness Avenue
SAN FRANCISCO CA 94102
(End of Appendix H)
SOUTHERN CALIFORNIA
EDISON
An EDISON INTERNATIONAL Company
Incorporated Cities and Counties Served by SCE
COUNTIES
Fresno Kern Madera Riverside Tuolumne
Imperial Kings Mono San Bernardino Tulare
Inyo Los Angeles Orange Santa Barbara Ventura
CITIES
Adelanto' Commerce Hesperia Los Alamitos Port Hueneme Simi Valley
Agoura Hills Compton Hidden Hills Lynwood Porterville South El Monte
Alhambra Corona Highland Malibu Rancho South Gate
Aliso Viejo Costa Mesa Huntington Mammoth Lakes Cucamonga South Pasadena
Apple Valley Covina Beach Manhattan Rancho Mirage Stanton
Arcadia Cudahy Huntington Park Beach Rancho Palos
Indian Wells Maywood Verdes Tehachapi
Artesia Culver City Temecula
Industry McFarland Rancho Santa
Avalon Cypress Inglewood Menefee Margarita Temple City
Baldwin Park Delano Irvine Mission Viejo Redlands Thousand Oaks
Barstow Desert Hot Redondo Beach Torrance
Springs Irwindale Monrovia
Beaumont Rialto Tulare
Diamond Bar Jurupa Valley Montclair
Bell Ridgecrest Tustin
Downey La Canada Montebello
Bell Gardens Flintridge Rolling Hills Twentynine Palms
Bellflower Duarte Monterey Park Upland
La Habra Moorpark Rolling Hills P
Beverly Hills Eastvale La Habra Estates
El Monte Heights Moreno Valley Valencia
Big Bear Lake Rosemead Victorville
Bishop El Segundo La Mirada Murneta San Bernardino Villa Park
Blythe Exeter La Palma Newport Beach San
Bradbury Farmersville
La Puente Norco Buenaventura Visalia
Fillmore La Verne Norwalk San Dimas Walnut
Brea West Covina
Fontana Laguna Beach Ojai San Fernando
Buena Park West Hollywood
Fountain Valley Laguna Hills Ontario San Gabriel
Calabasas Westlake Village
Fullerton Laguna Niguel Orange San Jacinto g
California City Westminster
Garden Grove Laguna Woods Oxnard San Marino
Calimesa Whittier
Gardena Lake Elsinore Palm Desert Santa Ana
Camarillo Wildomar
Glendora Lake Forest Palm Springs Santa Barbara
Canyon Lake Woodlake(Three
Goleta Lakewood Palmdale Santa Clarita
Carpinteria Santa Fe Rivers)
Carson Grand Terrace Lancaster Palos Verdes Springs Yorba Linda
Cathedral City Hanford Lawndale Paramount Santa Monica Yucaipa
Cerritos Hawaiian Gardens Lindsay Perris Santa Paula Yucca Valley
Chino Loma Linda Pico Rivera Seal Beach
Hawthorne Chino Hills Hemet Lomita Placentia
Sierra Madre
Pomona
Long Beach Signal Hill
Claremont Hermosa Beach
Last Updated 5/12/2014 Updated by Sylvia S Hernandez