HomeMy WebLinkAboutStaff Report 2608-6609CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, September 14, 2026
Council Chambers & Hybrid
5:30 PM
Agenda Item
5.Adopt a Resolution approving the City of Palo Alto Utilities Electric Utility Physical
Security Plan Update: CEQA Status – Not a Project
City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: September 14, 2026
Report #:2608-6609
TITLE
Adopt a Resolution approving the City of Palo Alto Utilities Electric Utility Physical Security Plan
Update: CEQA Status – Not a Project
RECOMMENDATION
Staff recommend that the City Council:
1. Adopt Resolution (Attachment A) approving the five-year review and update to the City
of Palo Alto Utilities Electric Physical Security Plan (Plan).
2. Authorize the Utilities Director to submit notice of the Council's approval of resolution
to the California Public Utilities Commission (CPUC) in accordance with Ordering
Paragraph 24 of CPUC Decision 19-01-018.
3. Authorize the Utilities Director, or designee, to make future administrative, technical,
editorial, or non-substantive revisions to the Plan as necessary, provided such revisions
do not materially alter the intent of the Plan or require further City Council action.
EXECUTIVE SUMMARY
The City of Palo Alto Utilities (CPAU) completed the required five-year review and update of its
Electric Physical Security Plan in accordance with CPUC Decision 19-01-018 (Phase I Decision on
Order Instituting Rulemaking Regarding the Physical Security of Electrical Corporations). The
update confirms that the Plan continues to meet the objectives of the Decision and reflects
current utility infrastructure, operations, risk assessments, and mitigation measures. The
update includes revisions to facility information, risk assessments, mitigation measures,
references, and administrative content to improve clarity, accuracy, and consistency. The City’s
Office of Emergency Services completed the independent review, and the Palo Alto Fire
Department completed the validation. Recognizing the need for confidentiality of its contents,
the City Manager has reviewed the plan and confirmed that no substantive policy issues are
raised by its findings and implementation. Staff recommend that the City Council adopt a
resolution approving the five-year review and update and authorizing the Utilities Director to
provide notice of the approval action to the CPUC.1
BACKGROUND
On April 16, 2013, the physical attack on Pacific Gas and Electric Company's Metcalf
Transmission Substation prompted federal and state efforts to strengthen electric utility
physical security. Following Senate Bill 699 (2014), the CPUC initiated a proceeding to develop
risk-based physical security standards for electric utilities.
In January 2019, the CPUC adopted Decision 19-01-018, which established an industry
framework for investor-owned and publicly owned electric utilities to identify “Covered
Distribution Facilities”, evaluate physical security risks, develop mitigation plans where
appropriate, obtain independent review, validate the assessment, and periodically review and
update their Utility Security Plans2.
On September 13, 2021, the City Council adopted Resolution No. 99853 approving CPAU's initial
Plan. That plan documented CPAU's evaluation of its electric distribution facilities, identified
Covered Distribution Facilities, assessed physical security risks, developed mitigation strategies
where appropriate, completed an independent third-party review and qualified authority
validation, and authorized staff to provide notice of plan adoption to the CPUC. The resolution
also directed CPAU to continue maintaining the Plan and to perform a review every five years.
DISCUSSION
The update represents a comprehensive review of the Plan and confirms that the Plan
continues to meet the objectives established by Decision D.19-01-018 while reflecting current
utility operations, infrastructure, and risk assessments.
CPAU followed the six-step process outlined in the Joint IOU/POU Straw Proposal and Decision
D.19-01-018, Section 6.1 to conduct its review and update.4
The six steps are as follows:
1 Per D.19-01-018 “24. Publicly Owned Utilities shall conduct a program review of their Security Plan and associated physical
security program every five years after initial approval of the Security Plan by their Board of Directors or City Council. Notice of
such approval action shall be provided to the Commission’s Safety and Enforcement Division within 30 days of Plan adoption by
way of copy of signed resolution or letter by a responsible elected- or appointed official, or utility director.” (see page 54 of D.
19-01-018 https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M260/K335/260335905.PDF.)
2 Per D.19-01-018 “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.)
3 Resolution No. 9985
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61446&dbid=0&repo=PaloAlto&searchid=c55f33a4-84b0-48aa-
aa61-74380efefe0d
4 Per D.19-01-018 , Section 6.1 “SED RASA recommends the following six-step procedure for carrying out new physical security
plan requirements to address utilities’ distribution assets. ” (see pages 32-34 of D. 19-01-018
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M260/K335/260335905.PDF.)
STEP 1: Assessment/Plan Development
CPAU staff and/or consultants prepare a Draft Utility Security Plan with any necessary updates
through the process set forth in Steps 1A, 1B, and 1C.
CPAU evaluates whether there are any changes in its facilities meeting D.19-01-018’s definition
of a “Covered Distribution Facility” using the seven factors identified in the Joint IOU/POU
Straw Proposal.
For every individual Covered Distribution Facility identified pursuant to Step 1A, CPAU performs
an evaluation of any updates to 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.
If there are any individual Covered Distribution Facilities where the Risk Assessment updates
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).
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. 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
conclusions of the Qualified Third-Party Reviewer, and CPAU’s responses to the Qualified Third-
Party Review will constitute CPAU’s Utility Security Plan. The City’s Qualified Third-Party
reviewer is the Palo Alto Office of Emergency Services.
CPAU submits 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: City Council Approval Action and Notice to CPUC
STEP 5: Maintenance
STEP 6: Repeat process
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
*NOT YET APPROVED*
027082126 1
Resolution No. _________
Resolution of the Council of the City of Palo Alto Approving the
2026 update to the City of Palo Alto Utilities Electric Physical
Security Plan
R E C I T A L S
A. On September 13, 2021, the City Council adopted Resolution No. 9985 approving
the City of Palo Alto Utilities Electric Physical Security Plan in accordance with California Public
Utilities Commission Decision 19-01-018; and
B. Ordering Paragraph 24 of Decision 19-01-018 requires publicly owned utilities to
conduct a program review of their Physical Security Plan and associated physical security
program every five years following the initial approval of the Physical Security Plan; and
C. The City of Palo Alto Utilities has completed the required five-year review and
update of its Electric Utility Physical Security Plan, including reevaluation of covered
distribution facilities, physical security measures, risk assessments, mitigation strategies, and
other applicable program elements; and
D. The Electric Utility Physical Security Plan 2026 update includes revisions necessary
to maintain compliance with Decision 19-01-018 and incorporates administrative updates,
current operational information, and other revisions as appropriate to reflect the City's
ongoing physical security program.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council affirms that Resolution No. 9985 remains in effect as the
original approval of the City's Electric Utility Physical Security Plan and hereby approves the
2026 update to the Physical Security Plan.
SECTION 2. The Council authorizes the Utilities Director to provide a signed copy of
this Resolution as notice of Council’s approval of the updated Physical Security Plan to the
California Public Utilities Commission Safety and Enforcement Division, together with any
supporting documentation required by Decision 19-01-018.
SECTION 3. 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, and authorizes
making future administrative, technical, editorial, or non-substantive revisions to the Physical
Security Plan as necessary, provided such revisions do not materially alter the Plan.
*NOT YET APPROVED*
027082126 2
SECTION 4. 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