HomeMy WebLinkAboutStaff Report 12218City of Palo Alto (ID # 12218)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 9/13/2021
City of Palo Alto Page 1
Title: Adoption of a Resolution Approving the City of Palo Alto's 2021 Electric
Utility Physical Security Plan
From: City Manager
Lead Department: Utilities
Recommendation
Staff recommends the City Council adopt a Resolution (Attachment A, Linked Document)
approving the City of Palo Alto’s 2021 Electric Utility Physical Security Plan.
Executive Summary
In January 2019 the California Public Utilities Commission (CPUC) approved Decision 19-01-
0181, requiring all electric utilities to develop and implement a plan which identifies electric
distribution assets that may require increased protection, and specifies measures to reduce
risks to those facilities. Ensuring the safety of its facilities is a top priority for City of Palo Alto
Utilities (CPAU), therefore, CPAU voluntarily participated in the CPUC’s Physical Security
proceeding and has undertaken this assessment. The overarching goal of the City’s Utility
Security Plan (Attachment B, Linked Document) is to describe CPAU’s risk management
approach toward physical security, with appropriate consideration of resiliency, impact, and
cost.
Background
On April 16, 2013, one or more individuals attacked equipment located within Pacific Gas and
Electric Company’s (PG&E) Metcalf Transmission Substation, ultimately damaging 17
transformers. These individuals also cut nearby fiber-optic telecommunication cables owned by
AT&T. In response, the Federal Energy Regulatory Commission (FERC) directed the North
American Electric Reliability Corporation (NERC) to develop new physical security requirements,
resulting in the creation of NERC’s critical infrastructure plan (CIP) standard CIP-0142. The goal
of CIP-014 is to enhance physical security measures for the most critical substations and control
centers in North America. Focused on the bulk power transmission system, CIP-014 does not
cover distribution facilities owned by City of Palo Alto.
1 D 19-01-018 is available at:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M260/K335/260335905.PDF.
2 https://www.nerc.com/_layouts/15/PrintStandard.aspx?standardnumber=CIP-014-
2&title=Physical%20Security&Jurisdiction=United%20States
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At the state level, Senator Jerry Hill authored Senate Bill (SB) 699 (2014), directing the California
Public Utility Commission (CPUC) to “consider adopting rules to address the physical security
risks to the distribution systems of electrical corporations.” The CPUC hosted a series of
workshops to better understand the state of utility physical security protections and to seek
input on refining their proposal.
In order to support a statewide improvement of how utilities address distribution-level physical
security risks, the California Municipal Utilities Association (CMUA), the statewide trade
association for POUs, coordinated with the state’s investor-owned utilities (IOUs) to develop a
comprehensive Straw Proposal3 (Joint IOU/POU Straw Proposal) for a process to identify at-risk
facilities and, if necessary, develop physical security mitigation plans. As a member of CMUA,
CPAU staff participated in the development of the Joint IOU/POU Straw Proposal through a
CMUA working group, as well as through direct meetings with the IOUs. The Joint POU/IOU
Straw Proposal set out a process: (1) identifying if the utility has any high priority distribution
facilities; (2) evaluating the potential risks to those high priority distribution facilities; (3) for the
distribution facilities where the identified risks are not effectively mitigated through existing
resilience/security measures, developing a mitigation plan; (4) obtaining third party reviews of
the mitigation plans; (5) adopting a document retention policy; (6) ensuring a review process
established by the POU governing board; and (7) implementing information sharing protocols.
In early 2019, the CPUC approved Decision (D.) 19-01-018, which adopted the Joint IOU/POU
Straw Proposal with additional clarifications and guidance. CPAU is issuing this report to reflect
its existing commitment to safety and to protecting its ratepayers’ investment by taking
reasonable and cost-effective measures to safeguard key distribution system assets.
Discussion
CPAU utilized a multi-step process to develop this Utility Security Plan (Linked Document) that
is consistent with the Joint IOU/POU Straw Proposal and D.19-01-018. The six steps of that
process are:
STEP 1: Assessment/Plan Development
CPAU staff and/or consultants prepare a Draft Utility Security Plan (Linked Document) through
the process set forth in Steps 1A, 1B, and 1C.
STEP 1A: Identify Covered Distribution Facilities
CPAU evaluates all distribution-level facilities in its service territory that are subject to its
control to determine if any facility meets D.19-01-018’s definition of a “Covered Distribution
Facility”4 using the seven factors identified in the Joint IOU/POU Straw Proposal.
3 Straw Proposal available at:
https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/R1506009-
Updated%20Joint%20Straw%20Proposal%20and%20Cover%20083117%20Filing.pdf.
4 Per D.19-01-018 at 26, “covered is the utility working group term employed to describe those assets that are applicable, or
that should be subject to physical security.” For purposes of this Plan, CPAU has determined that Covered Distribution Facilities
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STEP 1B: Perform risk assessment
For every individual Covered Distribution Facility identified pursuant to Step 1A, CPAU performs
an evaluation of the potential risks associated with a successful physical attack on that Covered
Distribution Facility, and whether existing grid resiliency, back-up generation, and/or physical
security measures appropriately mitigate identified risks.
STEP 1C: Develop mitigation plan
If there are any individual Covered Distribution Facilities where the Risk Assessment performed
pursuant to Step 1B finds that the existing mitigation and/or resiliency measures do not
effectively mitigate the identified risks, then CPAU will develop a Mitigation Plan for that
Covered Distribution Facility. The Mitigation Plan will use a risk-based approach to select
reasonable and cost-effective measures that can either be security focused (e.g., walls or
alarms) or resiliency focused (e.g., adequate spare parts).
STEP 2: Independent review
For every Utility Security Plan cycle, CPAU will document the results of the identification
process, risk assessment, and Mitigation Plan development performed pursuant to Steps 1A,
1B, and 1C. This documentation in combination with narrative descriptions constitutes CPAU’s
Draft Utility Security Plan. Each Draft Utility Security Plan is submitted to a Qualified Third Party
for Independent Review, which may be a governmental entity with demonstrated law
enforcement expertise.
The City’s Qualified Third-Party reviewer is the Palo Alto Office of Emergency Services. The
Qualified Third-Party Reviewer will then issue an evaluation that identifies any potential
deficiencies in the Draft Utility Security Plan as well as recommendations for improvements.
The combination of the Draft Utility Security Plan, the non-confidential conclusions of the
Qualified Third-Party Reviewer, and CPAU’s responses to the Qualified Third-Party Review will
constitute CPAU’s Utility Security Plan.
STEP 3: Validation
CPAU submitted its Utility Security Plan to a Qualified Authority for validation on the overall
adequacy of the Plan. The Qualified Authority must have sufficient familiarity with relevant
federal, state and local standards regarding critical asset protection and emergency response.
The City’s Fire Department agreed to serve as the Qualified Authority for this validation step,
and will provide additional feedback and evaluation of CPAU’s Utility Security Plan and may
deem the Utility Security Plan adequate.
STEP 4: Adoption
CPAU’s Utility Security Plan will be presented to and approved by the City Council at a public
meeting.
include Distribution Substations, but not Distribution Control Centers, since analysis of Distribution Control Centers is applicable
to Investor Owned Utilities only (see pages 35 and 49 of D. 19-01-018.)”
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STEP 5: Maintenance
CPAU will refine and update its Utility Security as appropriate and as necessary to preserve Plan
integrity.
STEP 6: Repeat process
CPAU will repeat the above five steps at least once every five years.
Council Adoption
Staff has completed Steps 1 through 3, and Council is being asked to approve the Utility
Security Plan (Step 4) via approval of the attached resolution (Linked Document), so that staff
may provide notice to the CPUC upon adoption. Although CPUC’s original deadline for Council
approval was July 10, 2021, CPAU, like many participating municipal utilities, required
additional time to identify a qualified authority willing and able to review its Plan. Staff has
informed CPUC of the updated timeline, which will be met upon Council approval of the
attached resolution (Linked Document). Staff will be responsible for Steps 5 and 6, which is the
ongoing plan maintenance and full review at least every five years.
Stakeholder Engagement
As a member of CMUA, CPAU staff participated in the development of the Joint IOU/POU Straw
Proposal through a CMUA working group as well as through direct meetings with the IOUs.
Following CPUC Decision 19-01-018, the CMUA coordinated with CPAU staff to develop the
Utility Security Plan.
Resource Impact
Existing staff resources in engineering and the City Attorney’s Office developed the framework
of the Plan, and the Plan itself. The Palo Alto Office of Emergency Services has performed the
Qualified Third-Party Review. The Palo Alto Fire Department performed the Third-Party
Qualified Authority Review at no cost to the City. Mitigation measures identified in the Plan
include electric substation physical security capital improvement plans (e.g. security fence,
lighting, and video upgrades) already in progress since FY19, with funding included in the FY
2021 Capital budget for EL-16003. Restoring resiliency to the electric power system feeding a
Covered Facility after a potential security breach would be accomplished using existing staff and
protocols in place for operation of electric equipment. Future mitigation measures identified as
necessary will be approved annually through the Capital and Operating Budget process.
Note that implementation of required mitigation could impact trees within substation
perimeters, and as such staff will endeavor to minimize any such impacts.
Policy Implications
Adopting a resolution approving the Utility Security Plan is in line with the Utilities Strategic
Plan to collaborate with government, trade, and regional agencies enhances our sphere of
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influence, allows us to identify common ground, and leverage economies of scale. (Priority #2,
Strategy #4).
Environmental Review
The Council’s decision to approve the Utility Security Plan does not meet the California
Environmental Quality Act’s (CEQA) definition of a project under Public Resources Code Section
21065 and CEQA Guidelines Section 15378(b)(5), because it is an operational activity which will
not cause a direct or indirect physical change in the environment, and therefore, no
environmental review is required. Individual upgrades or changes at utility facilities, if needed
as a result of the City’s implementation of the Plan, will be analyzed under CEQA.
Attachments:
• Attachment3.a: Attachment A: Resolution
• Attachment3.b: Attachment B: Electric Utility Security Plan
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Resolution No. ________
Resolution of the Council of the City of Palo Alto Approving the City of
Palo Alto’s 2021 Electric Utility Physical Security Plan
R E C I T A L S
A. On January 10, 2019, the California Public Utilities Commission (“CPUC”) approved
Decision (D.) 19-01-018 (“Decision”) requiring all electric utilities to develop and
implement a plan that (1) identifies electric distribution assets that require greater
protection; and (2) specifies measures to reduce the identified risks and threats to those
facilities (“Physical Security Plan”).
B. While City of Palo Alto Utilities (CPAU), like other publicly owned utilities (POUs), is not
subject to CPUC jurisdiction, safety is a top priority for POUs, so in the spirit of
continued voluntary cooperation, CPAU and other POUs agreed to draft Physical
Security Plans.
C. The Physical Security Plan attached is the public report on CPAU’s physical security
program for the electric distribution-level facilities that require evaluation under the
Decision.
D. The CPAU’s Physical Security Plan includes the following self-evaluation steps:
a. Identifies covered distribution facilities by analyzing all distribution-level facilities
in CPAU’s service territory, using seven screening factors.
b. Assesses the potential risks associated with a successful physical attack on each
covered facility and determines whether existing resiliency and/or physical
security measures appropriately mitigate identified risks.
c. Develops mitigation plans for any individual covered facilities as needed, using
reasonable and cost-effective measures.
E. The Plan also details ongoing maintenance practices and planned additions that will
ensure the physical safety of the identified facilities. This includes descriptions of
workforce training and imminent updates to facility designs, as needed.
F. Independent review steps follow CPAU’s self-evaluation:
a. Qualified Third-Party review. The Decision requires an entity independent of
CPAU with law enforcement and physical security expertise, such as the Palo
Alto Police Department, to evaluate and analyze the Physical Security Plan. The
Palo Alto Police Department’s Office of Emergency Services (OES) performed the
Qualified Third-Party review for this Plan in May, 2021, and supported the Plan’s
findings. It asserted that the Plan’s proposed actions would increase overall
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resilience. It listed a few specific areas that CPAU could focus on for additional
resiliency in the future, such as local generation and storage. CPAU agreed, also
noting the importance of local generation and storage.
b. Qualified Authority Validation. CPAU must submit its Utility Security Plan to a
Qualified Authority for validation on the overall adequacy of the Plan. The
Qualified Authority must have sufficient familiarity with relevant federal, state
and local standards regarding critical asset protection and emergency response.
The City’s Fire Department agreed to serve as the Qualified Authority for this
validation step, provide additional feedback and evaluation of CPAU’s Utility
Security Plan, and determine the Utility Security Plan’s adequacy. The Palo Alto
Fire Department performed the Qualified Authority Validation for this Plan in
August, 2021, and found that the plan logically identified known risks and
provided reasonable mitigation plans. CPAU accepted this conclusion and
restated its commitment to maintaining and improving its security measures.
G. With the completion of the Qualified Third-Party review and Validation, staff is
presenting the Physical Security Plan to Council for approval, and upon approval will
provide notice to the CPUC.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts a resolution approving CPAU’s 2021 Electric Utility
Physical Security Plan, as shown in Exhibit A, enabling CPAU to submit an executed copy of this
Resolution as notice of the Plan’s approval to CPUC.
SECTION 2. The Council directs CPAU staff to continue ongoing evaluation of the Physical
Security Plan as appropriate and necessary to preserve the Plan’s integrity, with a goal of
renewed evaluation every five years, as encouraged by CPUC guidelines.
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SECTION 3. The Council finds that the adoption of this resolution does not meet the definition
of a project under Public Resources Code Section 21065, thus, no environmental assessment
under the California Environmental Quality Act is required at present. Individual upgrades or
changes at utility facilities, if needed as a result of the City’s implementation of the Plan, will be
analyzed under CEQA.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
__________________________ _____________________________
Assistant City Attorney City Manager
_____________________________
Director of Utilities
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CITY OF PALO ALTO
ELECTRIC UTILITY
SECURITY
PLAN
PUBLIC REPORT ON CITY OF PALO ALTO’S PHYSICAL
SECURITY PROGRAM FOR ELECTRIC DISTRIBUTION-
LEVEL FACILITIES
May 5, 2021
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TABLE OF CONTENTS
I. Overview .............................................................................................................................................. 4
A. Goal of Utility Security Plan ............................................................................................................ 4
B. Description of CPAU ....................................................................................................................... 4
C. Results of Utility Security PLan Assessment ................................................................................... 4
II. Background .......................................................................................................................................... 6
III. Plan development process ................................................................................................................ 8
A. Physical Security Principles ............................................................................................................. 8
B. Utility Security Plan Development Process ................................................................................... 8
STEP 1: Assessment/Plan Development ............................................................................................. 8
STEp 1A: Identify Covered Distribution Facilities ............................................................................... 8
STEP 1B: Perform risk assessment ........................................................................................................ 9
STEP 1C: Develop mitigation plan ..................................................................................................... 9
STEP 2: Independent review ............................................................................................................... 9
STEP 3: Validation ................................................................................................................................. 9
STEP 4: Adoption ................................................................................................................................ 10
STEP 5: Maintenance ......................................................................................................................... 10
STEP 6: Repeat process ..................................................................................................................... 10
IV. Identification of covered distribution faciliites (Step 1A) .............................................................. 10
A. Identification Factors .................................................................................................................... 10
B. Identification analysis ................................................................................................................... 11
V. Risk assessment (Step 1B) .................................................................................................................. 13
A. Methodology ................................................................................................................................. 13
B. Mitigation Measures ..................................................................................................................... 13
C. Risk Assessment ............................................................................................................................. 15
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VI. Covered Distribution Facility Mitigation plans (Step 1C) .............................................................. 18
VII. Independent evaluation and Response (Step 2) .......................................................................... 19
A. Requirements for qualified third party review ........................................................................... 19
B. Identification of third party reviewer .......................................................................................... 19
C. Public results of third party evaluation ....................................................................................... 19
D. CPAU REsponse ............................................................................................................................. 19
VIII. Validation (Step 3) ............................................................................................................................. 20
A. Selection of qualified authority ................................................................................................... 20
B. Results of qualified authority review ........................................................................................... 20
C. CPAU Response to Qualied authority review ............................................................................ 20
IX. Narrative Descriptions for Utility Security Plan ................................................................................ 21
A. Asset Management program ...................................................................................................... 21
B. Workforce training and retention program ............................................................................... 21
C. Preventative maintenance plan ................................................................................................ 21
D. Physical security Event Training ................................................................................................... 21
E. Communication infrastructure risk assessment ......................................................................... 22
F. Facility design Features ................................................................................................................ 22
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CPAU Utility Security Plan
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I.OVERVIEW
A.GOAL OF UTILITY SECURITY PLAN
Ensuring the safety of its facilities is a top priority for City of Palo Alto Utilities (CPAU), and
CPAU prioritizes safety in all aspects of its design, operation, and maintenance
practices. The overarching goal of this Utility Security Plan is to describe CPAU’s risk
management approach toward distribution system physical security, with appropriate
consideration of resiliency, impact, and cost.
CPAU recognizes the importance of securing the safety and reliability of its electric
system and, therefore, CPAU voluntarily participated in the California Public Utilities
Commission’s (CPUC) Physical Security proceeding and has undertaken this
assessment. In the spirit of continued voluntary cooperation, CPAU offers the following
in response to CPUC Decision 19-01-018.
B.DESCRIPTION OF CPAU
CPAU is a municipal utility that operates in the charter city of Palo Alto, California. CPAU
serves approximately 30,000 customers in an urban setting via 9 distribution substations
consisting of 9 miles of subtransmission lines and 307 distribution lines across 26 square
miles. Nine of these substations meet the definition of Distribution Substation1 as each is
considered an electrical power substation associated with the distribution system and
the primary feeders for supply to residential, commercial and/or industrial loads.
C. RESULTS OF UTILITY SECURITY PLAN ASSESSMENT
CPAU applied the methodology described in Section 3B of this document to identify
Covered Distribution Facilities2, assess the risk of a successful physical attack, identify
preliminary mitigation measures, secure Third Party Verification, and develop and
implement a Final Security Plan, consistent with D.19-01-018. Three Covered Distribution
Facilities’ loads, which serve a wastewater treatment facility and Level 1 trauma
centers, are served by 2 substations. Based on this assessment, additional mitigation
measures are recommended at 1 substation, to reduce the effective risk level from MID
to LOW. The mitigation projects identified within this Plan will reduce this level from MID
to LOW, including enhanced physical security protections to reduce the likelihood of
1 Per D.19-01-018 at 23, “The Joint Utility Proposal defines Distribution Substation as an electric power
substation associated with the distribution system and the primary feeders for supply to residential,
commercial and/or industrial loads.
2 Per D.19-01-018 at 25, note 49, “Distribution Facilities” include “A Distribution Substation or Distribution
Control Center.”
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May 5, 2021 – Step 2; Independent Review - Complete 5
attack, and site improvement projects to eliminate access. All other Distribution
Facilities have LOW or negligible risk and, consistent with the Joint Utility Proposal
described in D.19-01-018, were not further evaluated.
The City’s Office of Emergency Services (OES), on behalf of the Palo Alto Police
Department, is the third party reviewing entity. The OES Chief is a sworn law
enforcement officer.
Palo Alto OES supports the internal risk and threat profiles identified by CPAU and the
proposed mitigation measures and corrective actions.
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CPAU Utility Security Plan
May 5, 2021 – Step 2; Independent Review - Complete 6
II.BACKGROUND
On April 16, 2013, one or more individuals attacked equipment located within Pacific Gas and
Electric Company’s (PG&E) Metcalf Transmission Substation, ultimately damaging 17
transformers. These individuals also cut nearby fiber-optic telecommunication cables owned by
AT&T. In response to the attack, the Federal Energy Regulatory Commission (FERC) directed the
North American Electric Reliability Corporation (NERC) to develop new physical security
requirements, resulting in the creation of CIP-014.
At the state level, Senator Jerry Hill authored SB 699 (2014), directing the CPUC to
“consider adopting rules to address the physical security risks to the distribution systems of
electrical corporations.” In response to SB 699, the CPUC’s Safety and Enforcement Division, Risk
Assessment and Safety Advisory Section (RASA) prepared a white paper proposing a new
requirement for investor owned utilities (IOUs) and publicly owned utilities (POUs) to develop
security plans that would identify security risks to their distribution and transmission systems, and
propose methods to mitigate those risks. The CPUC hosted a series of workshops to better
understand the state of utility physical security protections and to seek input on refining their
proposal.
In order to support a statewide improvement of how utilities address distribution level physical
security risks, the California Municipal Utilities Association (CMUA), which is the statewide trade
association for POUs, coordinated with the state’s IOUs to develop a comprehensive Straw
Proposal3 (Joint IOU/POU Straw Proposal) for a process to identify at-risk facilities and, if
necessary, develop physical security mitigation plans. As a member of CMUA, CPAU staff
participated in the development of the Joint IOU/POU Straw Proposal through a CMUA working
group as well as through direct meetings with the IOUs. The Joint POU/IOU Straw Proposal set out
a process for the following: (1) identifying if the utility has any high priority distribution facilities; (2)
evaluating the potential risks to those high priority distribution facilities; (3) for the distribution
facilities where the identified risks are not effectively mitigated through existing resilience/security
measures, developing a mitigation plan; (4) obtaining third party reviews of the mitigation plans;
(5)adopting a document retention policy; (6) ensuring a review process established by the POU
governing board; and (7) implementing information sharing protocols.
RASA filed a response4 to the Joint IOU/POU Straw Proposal that recommended various
modifications and clarifications, including a six-step process. Additionally, RASA recommended
that the utility mitigation plans include: (1) an assessment of supply chain vulnerabilities; (2)
training programs for law enforcement and utility staff to improve communication during
physical security events; and (3) an assessment of any nearby communication utility
infrastructure that supports priority distribution substations.
3 Straw Proposal available at: https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/R1506009-
Updated%20Joint%20Straw%20Proposal%20and%20Cover%20083117%20Filing.pdf.
4 RASA Response available at: https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/Final%20Staff%20Recommendation%20for%20Commission%20Consideration%20010318.pdf.
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In early 2019, the CPUC approved Decision (D.) 19-01-018, which adopted the Joint IOU/POU
Straw Proposal as modified by the RASA proposal, with additional clarifications and guidance.
D.19-01-018 clarified that where there is a conflict between the Straw Proposal and the RASA
proposal, then it is the rule in the RASA proposal that controls.5
D.19-01-018 asserted that the POUs should utilize the Utility Security Plan process described
therein. CPAU is following the process and issuing this report at this time to reflect its existing
commitment to safety and to protecting its ratepayers’ investment by taking reasonable and
cost-effective measures in an effort to safeguard key assets of its distribution system.
5 D.19-01-018 at 43, footnote 58 (“Should there be any question of which shall predominate should there be any incongruity or conflict between a utility or SED RASA recommended rule, the SED RASA rule shall apply.”).
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CPAU Utility Security Plan
May 5, 2021 – Step 2; Independent Review - Complete 8
III. PLAN DEVELOPMENT PROCESS
A. PHYSICAL SECURITY PRINCIPLES
The Joint IOU/POU Straw Proposal seeks to support the creation of a risk management approach
toward distribution system physical security, with appropriate considerations of resiliency,
impact, and cost. In order to accomplish this risk-based approach, the Joint IOU/POU Straw
Proposal identifies several principles to guide the development of each individual utility’s
program. These principles are the following:
1. Distribution systems are not subject to the same physical security risks and associated
consequences, including threats of physical attack by terrorists, as the transmission
system.
2. Distribution utilities will not be able to eliminate the risk of a physical attack occurring,
but certain actions can be taken to reduce the risk or consequences, or both, of a
significant attack.
3. A one-size-fits-all standard or rule will not work. Distribution utilities should have the
flexibility to address physical security risks in a manner that works best for their systems
and unique situations, consistent with a risk management approach.
4. Protecting the distribution system should consider both physical security protection and
operational resiliency or redundancy.
5. The focus should not be on all Distribution Facilities, but only those that risk dictates
would require additional measures.
6. Planning and 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 or mitigate the potential consequences of such attacks.
B. Utility Security Plan Development Process
CPAU utilized a multi-step process to develop this Utility Security Plan that is consistent with the
Joint IOU/POU Straw Proposal and D.19-01-018. The relevant six steps of that process are the
following:
STEP 1: ASSESSMENT/PLAN DEVELOPMENT
CPAU staff prepares a Draft Utility Security Plan through the process set forth in Steps 1A, 1B, and
1C.
STEP 1A: IDENTIFY COVERED DISTRIBUTION FACILITIES
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CPAU Utility Security Plan
May 5, 2021 – Step 2; Independent Review - Complete 9
CPAU will evaluate all distribution-level facilities in its service territory that are subject to its control
to determine if any facility meets D.19-01-018’s definition of a “Covered Distribution Facility”6
using the seven factors identified in the Joint IOU/POU Straw Proposal.
STEP 1B: PERFORM RISK ASSESSMENT
For every individual Covered Distribution Facility identified pursuant to Step 1A, CPAU will perform
an evaluation of the potential risks associated with a successful physical attack on that Covered
Distribution Facility, and whether existing grid resiliency, back-up generation, and/or physical
security measures appropriately mitigate identified risks.
STEP 1C: DEVELOP MITIGATION PLAN
If there are any individual Covered Distribution Facilities where the Risk Assessment performed
pursuant to Step 1B finds that the existing mitigation and/or resiliency measures do not
effectively mitigate the identified risks, then CPAU will develop a Mitigation Plan for that Covered
Distribution Facility. The Mitigation Plan will use a risk-based approach to select reasonable and
cost-effective measures that can either be security focused (e.g., walls or alarms) or resiliency
focused (e.g., adequate spare parts).
STEP 2: INDEPENDENT REVIEW
For every Utility Security Plan cycle, CPAU will document the results of the identification process,
risk assessment, and Mitigation Plan development performed pursuant to Steps 1A, 1B, and 1C.
This documentation in combination with narrative description in Section IX below, constitutes
CPAU’s Draft Utility Security Plan. Each Draft Utility Security Plan is submitted to a Qualified Third
Party for Independent Review. The Qualified Third Party Reviewer will then issue an evaluation
that identifies any potential deficiencies in the Draft Utility Security Plan as well as
recommendations for improvements. CPAU will then modify its plan to address any identified
deficiencies or recommendations, or will document the reasons why any recommendations
were not adopted. The combination of the Draft Utility Security Plan, the non-confidential
conclusions of the Qualified Third Party Reviewer, and CPAU’s responses to the Qualified Third
Party Review will constitute CPAU’s Utility Security Plan.
STEP 3: VALIDATION
6 Per D.19-01-018 at 26, “covered is the utility working group term employed to describe those assets that
are applicable, or that should be subject to physical security.” For purposes of this Plan, CPAU has
determined that Covered Distribution Facilities include Distribution Substations, but not Distribution Control
Centers, since analysis of Distribution Control Centers is applicable to Investor Owned Utilities only (see
pages 35 and 49 of D. 19-01-018.)”
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CPAU Utility Security Plan
May 5, 2021 – Step 2; Independent Review - Complete 10
CPAU will submit its Utility Security Plan to a qualified authority for review. Such entity will provide
additional feedback and evaluation of CPAU’s Utility Security Plan and, to the extent that this
entity is authorized, such entity may deem the Utility Security Plan as adequate.
STEP 4: ADOPTION
CPAU’s Utility Security Plan will be presented to and adopted by City of Palo Alto Council at a
public meeting.
STEP 5: MAINTENANCE
CPAU will refine and update the Utility Security as appropriate and as necessary to preserve plan
integrity.
STEP 6: REPEAT PROCESS
CPAU will repeat this six step process at least once every five years.
IV. IDENTIFICATION OF COVERED DISTRIBUTION FACILIITES (STEP 1A)
As described in Section III, Step 1A of the Utility Security Plan process involves assessing all
distribution-level facilities that are subject to the control of CPAU to determine which facilities are
“Covered Distribution Facilities” subject to the need for a risk assessment. This Section describes
the factors that CPAU used to evaluate its distribution facilities and the results of its evaluation.
A. IDENTIFICATION FACTORS
The Joint IOU/POU Straw Proposal defines seven screening factors to determine if a facility is a
“Covered Distribution Facility.” Some factors require additional definitions and/or clarifications in
order to be applied to CPAU’s facilities. The following Table provides the Joint IOU/POU Straw
Proposal’s Factors as modified/clarified by CPAU.
Factor Joint IOU/POU Straw Proposal Description Facilities Covered with Additional Clarifications
1
Distribution Facility necessary for crank path,
black start or capability essential to the
restoration of regional electricity service that are not subject to the California Independent System Operator’s (CAISO)
operational control and/or subject to North
American Electric Reliability Corporation (NERC) Reliability Standard CIP-014-2 or its
successors
CPAU has no black start facilities within
its service territory.
2 Distribution Facility that is the primary source of electrical service to a military installation
essential to national security and/or
There are no military installations as defined here essential for national
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emergency response services (may include
certain airfields, command centers,
weapons stations, emergency supply
depots)
security or emergency response within
CPAU’s service territory.
3
Distribution Facility that serves installations
necessary for the provision of regional
drinking water supplies and wastewater services (may include certain aqueducts,
well fields, groundwater pumps, and
treatment plants)
CPAU has a regional Water Quality
Control Plant in its service territory that
provides wastewater services to the City of Palo Alto and surrounding cities
with a combined population of over
100,000. See
https://www.cleanbay.org/regional-water-quality-control-plant/regional-
water-quality-control-plant
4
Distribution Facility that serves a regional public safety establishment (may include
County Emergency Operations Centers;
county sheriff’s department and major city police department headquarters; major state and county fire service headquarters;
county jails and state and federal prisons;
and 911 dispatch centers)
There are no regional public safety establishments as defined here in
CPAU’s service territory.
5
Distribution Facility that serves a major
transportation facility (may include
International Airport, Mega Seaport, other air traffic control center, and international
border crossing)
There are no major transportation
facilities as defined here in CPAU’s
service territory.
6
Distribution Facility that serves as a Level 1 Trauma Center as designated by the Office
of Statewide Health Planning and
Development
CPAU identified two Level 1 Trauma Centers in its service territory – the
Stanford Hospitals at two locations
within Palo Alto. See
https://stanfordhealthcare.org/for-patients-visitors/locations-and-
parking.html
7
Distribution Facility that serves over 60,000 meters CPAU does not have a Distribution Facility that serves over 60,000 meters.
CPAU serves 29,136 meters. See
https://www.cityofpaloalto.org/civicax/filebank/documents/16777/
B. IDENTIFICATION ANALYSIS
In performing this identification analysis, CPAU assessed all distribution level facilities that are
subject to its exclusive control. The specific types of facilities include substations.
Based on this scope, CPAU has identified 9 facilities that are subject to this identification analysis.
Of these 9 facilities, 3 fall within 1 of the categories listed above. These 3 facilities listed below
constitute CPAU’s “Covered Distribution Facilities.”
The following table summarizes the results of CPAU’s identification analysis.
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Facility ID 1. Crank Path, Black Start
2. Military Installation 3. Regional Drinking Water/ Wastewater Services
4. Regional Public Safety
5. Major Transportation Facility
6. Level 1 Trauma Center 7. Over 60,000 Meters
Substation 1 New Stanford
Hospital at 500 Pasteur Drive
Substation 2 Old Stanford Hospital at 300 Pasteur Drive
Substation 3 Water Quality
Control Plant at 2501 Embarcadero Way
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V. RISK ASSESSMENT (STEP 1B)
A. METHODOLOGY
Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, CPAU
assessed the potential risks associated with a successful physical attack on each of the Covered
Distribution Facilities identified in Section IV above. For purpose of this analysis, a physical attack
is limited to the following: (1) theft; (2) vandalism; and (3) discharge of a firearm. A “successful
physical attack” is limited to circumstances where a theft, vandalism, and/or the discharge of a
firearm has directly led to the failure of any elements of the Covered Distribution Facility that are
necessary to provide uninterrupted service to the specific load identified in Section IV.
In order to perform this risk analysis, CPAU evaluated the relative risk that (1) a physical attack on
a Covered Distribution Facility will be successful considering the protective measures in place; or
(2) that the impacts of a successful attack will be mitigated due to resiliency and other measures
in place.
B. MITIGATION MEASURES
D.19-01-018 identifies the specific mitigation measures that a utility should consider when
performing this risk analysis. The following table lists these mitigation measures and provides
CPAU’s additional clarifications that are necessary to apply these measures to CPAU’s territory.
Measure D.19-01-018 Description Additional Clarification
1
The existing system resiliency and/or
redundancy solutions (e.g., switching the load to another substation or circuit
capable of serving the load, temporary
circuit ties, mobile generation and/or
storage solutions).
CPAU evaluated the existing system’s
resiliency and redundancy options. CPAU determined that no additional
mitigation measures are needed,
because all three CPAU Covered
Distribution Facilities are fed from circuit feeders that are redundant or
can be switched to another circuit
feeder from another substation bank.
2
The availability of spare assets to restore a
particular load.
CPAU evaluated the type and
number of compatible spare units
available for the 3 Covered
Distribution Facilities. CPAU determined that no additional
mitigation measures are needed,
because if primary circuit feeder
breakers, switchgear, power transformers, bus, and/or bus
equipment are damaged, the
backup substation bank could be
switched to the respective Covered Distribution Facility to restore service
and prevent an extended outage.
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3
The existing physical security protections to
reasonably address the risk.
CPAU evaluated the site-specific
physical security barriers and
deterrents above and beyond
standard physical security measures, such as remotely monitored alarm,
lighting, camera systems, and security
walls and fences on the Distribution
Facility perimeters. Some of these measures, including minimal cameras
and lighting, a secure fence at one of
the facilities, and one door alarm, are
currently in place for the 3 Covered Distribution Facilities.
To enhance their physical security an
upgrade is planned for 2022-2023. The
construction set for the remaining
security measures will be issued for bid
in the Summer of 2021 (See 2021.0305 CPA PACKAGE 1 SUBSTATION LTG BID SET (1)).
4
The potential for emergency responders to identify and respond to an attack in a timely manner.
CPAU evaluated each Covered Facility and determined that no additional mitigation measures are
needed, based on the likelihood that
a law enforcement officer could arrive at the Covered Distribution Facility
within 15 minutes of a report from the
public or from CPAU Utilities Dispatch
that a facility alarm had been
triggered.7
5
Location and physical surroundings, including proximity to gas pipelines and
geographical challenges, and impacts of
weather.
CPAU evaluated this element based on the proximity of the Covered
Distribution Facility to populated areas
and the extent to which the interior of
the facility is shielded from view and access due to walls, vegetation, or
other physical obstructions. Only
Substation 3’s physical surroundings
may potentially be subject to added risk, due to the adjacent creek.
To mitigate access from the creek adjacent to Substation 3, a concrete security wall is planned to be
constructed in 2022.
6 History of criminal activity at the Distribution Facility and in the area. CPAU evaluated the property crime rates in the immediate vicinity of the
7 The City’s Police Department confirmed these response time estimates on March 10, 2021.
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Covered Distribution Facilities and
compared those crimes rates to
property crime rates for the county
and the state to determine if the area is subject to a higher than average
incidence of property related crimes.
Based on this evaluation, a concrete security wall is planned to be
constructed in 2022 surrounding
Substation 3.
7
The availability of other sources of energy
to serve the load (e.g., customer owned
back-up generation or storage solutions).
Of the three Covered Distribution
Facilities, one, the New Stanford
Hospital has full customer-owned
back-up generation capability.8
8
The availability of alternative ways to meet
the health, safety, or security.
The risk levels and mitigation measures
assessed as part of this Plan are sufficient to meet the needs served by
CPAU’s critical load.
9
Requirements served by the load (e.g.,
back up command center or water
storage facility).
Inherent to the identification
methodology considered, the critical
loads and corresponding Covered
Distribution Facilities were selected based on criteria above and lack of alternatives available to provide that
service.
Therefore, the requirements served by the load were already considered in
the identification and not further
contemplated as part of this
assessment.
C. RISK ASSESSMENT
Based on the process described in the Joint IOU/POU Straw Proposal and the direction provided
in D.19-01-018, CPAU has determined that existing programs and measures effectively mitigate
the risks of a physical attack to LOW for 2 of the 3 Covered Distribution Facilities in Section IV.
CPAU’s overall approach to security at all of these substations is to detect, delay or deter most
potential adversaries in the timeframe needed to initiate a response that has a reasonable
expectation of preventing or containing a catastrophic, negative event. CPAU’s overall
prudent utility management and system resiliency measures already in place also serve as
mitigation against any impacts of an attempted or successful attack.
Physical security is accomplished through perimeter fence, electronic security, and lighting
improvements. This applies to all three Covered Distribution Facilities. However, Substation 3 is
8 Confirmed by Stanford’s Assistant Chief Engineer on 4/8/21.
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assessed a risk level of MID due to its location and a modest level of increased criminal activity in
that area compared to the others.
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The following table provides a summary of CPAU’s assessment of each mitigation measure for
each Covered Distribution Facility.
Facility ID 1. Existing Resiliency 2. Spare Assets 3. Existing Physical Security
4. Emergency Responders 5. Location 6. Criminal History
7. Back up Generation 8-9. Alternate Solution
Risk Level
Substation
1
Fully
Effective
Fully
Effective
In Place
/ Partly
Effective
PAPD, primary
responder.9
Fully
Effective
Fully
Effective
Fully
Effective
N/A LOW
Substation 2 Fully Effective Fully Effective In Place / Partly Effective
PAPD, primary
responder9
Fully Effective Fully Effective Fully Effective N/A LOW
Substation 3 Fully Effective Fully Effective In Place / Partly Effective
PAPD, primary
responder9
In Place / Partly Effective
In Place / Partly Effective
Fully Effective N/A MID
As identified above, based on the existing protection and control mitigation measures in place,
2 of the 3 Distribution Facilities have a LOW effective risk level. As it is CPAU’s goal to operate the
distribution system at as low a risk level as practical, the risk of a successful physical security
breach on these Distribution Facilities was determined to be properly mitigated at these 2
locations. However, one Covered Facility was assessed to be a MID level of risk, indicative that
additional mitigation measures may be needed to properly reduce the effective risk level to
LOW. This facility is discussed in Section VI.
9 While Palo Alto’s Police Department staff will be the primary responder in an emergency, the City of Palo Alto has mutual aid agreements in place with other local agencies that could be called upon as a backup if necessary.
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VI. COVERED DISTRIBUTION FACILITY MITIGATION PLANS (STEP 1C)
Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, CPAU
has determined that for 1 of the Covered Distribution Facilities that is subject to CPAU’s control,
the existing mitigation measures may not effectively reduce the risk of a physical security attack
to LOW. This section describes the Mitigation Plan that CPAU has developed for this Covered
Distribution Facility.
To protect the primary Distribution substation Facilities providing power to the Water Quality
Control Plant wastewater facility, additional physical security matters could be taken at
Substation 3 to mitigate the risk of attack to LOW. The Distribution Facilities at risk from vandalism
and discharge of firearm are circuit feeder breakers, switchgear, power transformer, bus, and/or
bus equipment. The risk level is due in part to potential access to the site from the adjacent
creek.
Thus, the mitigation plan is to enhance the remotely monitored alarms, lighting, and camera
systems and add security walls on the Distribution Facility perimeters. A bid for construction of
these security measures will be issued in the Spring of 2021. (See 2021.0305 CPA PACKAGE 1
SUBSTATION LTG BID SET (1)). The cost of the alarms, lighting, and camera systems at these
Covered Distribution Facilities is estimated to be $500,000, with an estimated completion in 2023.
The security walls are an additional $1,500,000 with an estimated completion in 2023.
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VII. INDEPENDENT EVALUATION AND RESPONSE (STEP 2)
A. REQUIREMENTS FOR QUALIFIED THIRD PARTY REVIEW
D.19-01-018 specifies the following criteria for a Qualified Third Party Reviewer:
Independence: A Qualified Third Party Reviewer cannot be a division of the POU. A governmental entity can select as the third-party reviewer another governmental entity
within the same political subdivision, so long as the entity has the appropriate expertise,
and is not a division of the POU that operates as a functional unit, i.e., a municipality could use its police department as its third-party reviewer if it has the appropriate expertise.
Adequate Qualifications: A Qualified Third Party Reviewer must be an entity or
organization with electric industry physical security experience and whose review staff
has appropriate physical security expertise, which means that it meets at least one of the
following: (1) an entity or organization with at least one member who holds either an ASIS
International Certified Protection Professional (CPP) or Physical Security Professional (PSP) certification; (2) an entity or organization with demonstrated law enforcement,
government, or military physical security expertise; or (3) an entity or organization
approved to do physical security assessments by the CPUC, Electric Reliability
Organization, or similar electrical industry regulatory body.
B. IDENTIFICATION OF THIRD PARTY REVIEWER
CPAU has selected as its Third Party Reviewer the Palo Alto Police Department. The Palo Alto
Police Department is a department of the City of Palo Alto, independent of CPAU. Both CPAU
and the Palo Alto Police Department operate as independent functional units of the City of Palo
Alto. The Palo Alto Police Department has demonstrated law enforcement and physical
security expertise.
C. PUBLIC RESULTS OF THIRD PARTY EVALUATION
The City’s Office of Emergency Services (OES) has reviewed this document and supports the
findings herein.
OES further asserts that many of the proposed actions will also increase resilience to other threats
and hazards, such as outlined in the Threat Hazard Identification and Risk Assessment (THIRA)
report available on www.cityofpaloalto.org/thira.
OES suggests that CPAU continue work to support local generation (renewables) and storage
(battery systems), especially for key loads and systems, including: micro grids, distributed energy
resources (DER), mobile/portable solar-battery systems, and so on.
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D. CPAU RESPONSE
CPAU agrees with OES’ conclusions and recommendations. CPAU looks forward to continuing
to enhance the safety and reliability of its electric distribution system, including continued
emphasis on local generation, microgrids and distributed energy resources to support resiliency.
VIII. VALIDATION (STEP 3)
A. SELECTION OF QUALIFIED AUTHORITY
As an additional level of review, the Utility Security Plan of any publicly owned utility (POU) must
be submitted to a “qualified authority,” which must make a recommendation on the overall
adequacy of the plan.
CPAU has determined that the Palo Alto Fire Department has sufficient familiarity with relevant
federal, state, and local standards relating to critical asset protection and emergency response
in order to serve as the “qualified authority” for the review of CPAU’s Utility Security Plan. The
Palo Alto Fire Department has relevant experience in its role as public safety.
On August 6, 2021, CPAU received the Palo Alto Fire Department’s review of its draft Utility
Security Plan. The scope of the Palo Alto Fire Department’s review is to assess the overall
adequacy of plan, considering any relevant federal, state, local, and industry standards with
which the Palo Alto Fire Department is familiar.
B. RESULTS OF QUALIFIED AUTHORITY REVIEW
The Palo Alto Fire Department’s level of review involved checking the Plan for basic
adequacy. The Palo Alto Fire Department cannot opine on whether the Plan complies
with the CPUC Order or other specific laws or standards. The Palo Alto Fire Department
opinion is limited to “validating” the plan’s adequately in addressing key physical security
risks to the CPAU substations, and the perceived effectiveness of the mitigation measures
identified in the plan.
The Palo Alto Fire Department has concluded that the plan appears logical and
identifies known risks associated with the Substations of Palo Alto Utilities and provides
reasonable mitigation plans to address those risks.
C. CPAU RESPONSE TO QUALIED AUTHORITY REVIEW
CPAU accepts the Palo Alto Fire Department’s conclusion and will endeavor to maintain
and improve its security measures.
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IX. NARRATIVE DESCRIPTIONS FOR UTILITY SECURITY PLAN
A. ASSET MANAGEMENT PROGRAM
It is not feasible to maintain a stock of the wide variety of potential parts needs for the 3
Covered Facilities described here, due to the custom nature of most pieces and impracticality
of managing that extensive and expensive stock. CPAU has one spare breaker that is lightly
used and could serve as a spare; and CPAU’s fabrication shop could potentially remake a
damaged bus. CPAU has determined that the best option for locating spare parts in an
emergency is to contact the original equipment vendors via nameplate data.
Securing a spare part via original vendors would occur within one day, if the part is currently
manufactured or available via resellers. The process would begin with research to identify the
part and manufacturer, then contact with the manufacturer’s representative for an emergency
lead-time quote. For material that is currently manufactured, CPAU can typically source from
the manufacturer’s spare stock or from a neighboring utility within 1 day. However, many of
CPAU’s breakers, transformers, and switchgear are no longer manufactured. In this case, CPAU
would contact resellers. If the part is available, it can be shipped within 1 day. If the part is not
found, CPAU would do an emergency replacement of the entire system with an available
material. This would take longer, perhaps weeks for a breaker and months for a transformer or
switchgear lineup.
B. WORKFORCE TRAINING AND RETENTION PROGRAM
CPAU provides workforce training through apprentice programs,10 2000 hours of on the job
training per year, 2 weeks of in classroom and practical field instruction training per year. CPAU
staff also attend internal programs consisting of substation and distribution switching clearance
procedures, and job briefings, to retain and share knowledge. As CPAU’s territory and staffing is
small, the same staff that performs maintenance is cross-trained to effectively make repairs, with
the addition of potentially available contractors.
C. PREVENTATIVE MAINTENANCE PLAN
CPAU’s primary mitigation plan is to use field switches to switch loads to alternative circuit
feeders when one substation is inoperable. Staff executes special switching orders, moving the
load around to deenergize switches and feeders, which present opportunities to exercise the
switches. In addition, the alternative circuit feeders are currently energized with other loads,
essentially placing them in standby mode, meaning the conductors and switches are warm and
free of moisture and therefore readily available for use.
D. PHYSICAL SECURITY EVENT TRAINING
10 Curriculum may be found here: https://lineman.edu/business/2021-lineman-apprenticeship-program-catalog/.
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CPAU ensures staff readiness through the regular workforce training programs described above,
rather than through special event trainings.
E. COMMUNICATION INFRASTRUCTURE RISK ASSESSMENT
CPAU’s primary operation method for its distribution system is physical, in-person field operation
of its infrastructure. Therefore, CPAUs vulnerability to communication threats is LOW.
F. FACILITY DESIGN FEATURES
CPAU is focusing on features that highlight potential attackers with outward facing lighting and
accompanying infrared pan/tilt/zoom (PTZ) cameras, removing vegetation that provides hiding
areas, and replacing climbable fence sections. In addition, CPAU will staff substations to the
extent feasible during high threat situations, such as an elevated recommendation from the
federal government regulatory agency, NERC. This could consist of a 24/7 presence, or a nightly
presence, depending on the recommendation and severity of the threat.
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