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CPUC Issues Staff Report on Physical Security of Substations

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The Risk Assessment & Safety Advisory section of the CPUC's Safety & Enforcement Division has issued a new whitepaper titled, "Security and Resilience for California Electric Distribution Infrastructure: Regulatory and Industry Response to SB 699".


The report assesses the readiness of California's three primary electric utility companies to respond to a terrorist attack and the grid's ability to withstand an organized attack, and makes recommendations for low-cost practical solutions that would further enhance grid security and reduce the risk of a terrorist attack.


The report builds upon a previously issued Safety & Enforcement Division whitepaper from February 2015 that provided valuable information for a CPUC proceeding looking into Physical Security of the Electric Distribution Infrastructure (R.15-06-009). This Rulemaking was initiated in response to Senate Bill 699, a 2014 law directing the CPUC to assess grid vulnerability in the wake of an attack at Pacific Gas and Electric Company's Metcalf electric transmission substation on the southern outskirts of San Jose. The Metcalf attack also triggered sweeping new federal regulations to prevent such attacks against the high-voltage transmission grid under federal jurisdiction.


The CPUC report issued today focuses on potential gaps in federal rules (known as Critical Infrastructure Protection - CIP) for physical security of the distribution grid, overseen by the CPUC, in particular distribution substations and control centers.  


California's investor-owned electric utilities, as well as several publicly owned utilities, are considered leaders nationally in the emerging field of utility threat assessment and physical security. The CPUC report finds that although California's electric utilities are doing a good job of proactively taking steps to secure their electric distribution assets, they still have some ways to go to fully satisfy State regulators. 


Rather than focusing solely on "hardening" the physical security of facilities, the report recommends that all electric utilities operating in California boost resiliency - a facility's ability to withstand an attack and the grid's ability to withstand potential loss of a substation.


Recommended strategies include:

  • Maintaining an inventory of spare parts that can be rapidly dispatched and installed by utility repair crews;
  • Participation in assistance assurance agreements such as those that utilities have invoked for fires and major event relief efforts in California and nationally; and,
  • New standards for construction of new utility substations that would require defensibility as a design consideration. 


Separately, the CPUC in R.15-06-009 is considering a Joint Utility Proposal for Distribution Substation and Distribution Control Center Security Programs and Mitigation Plans. This first-of-its-kind proposal at the state level would consist of these elements:

  1. Identification of distribution facilities;
  2. Assessment of physical security risk on distribution facilities;
  3. Development and implementation of security plan;
  4. Verification;
  5. Recordkeeping
  6. Timelines; and,
  7. Cost recovery.                                                        

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