BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 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 Corporations Consistent with Public Utilities Code Section 364 and to Establish Standards for Disaster and Emergency Preparedness Plans for Electrical Corporations and Regulated Water Companies Pursuant to Public Utilities Code Section Rulemaking (Filed June 11, 2015) JOINT PARTIES FILING OF UPDATED DRAFT STRAW PROPOSAL FOR PHYSICAL SECURITY REGULATIONS GLORIA ING ROBERT KANG Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Ave. Rosemead, CA Telephone: (626) Facsimile: (626) Dated: August 31, 2017

2 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 Corporations Consistent with Public Utilities Code Section 364 and to Establish Standards for Disaster and Emergency Preparedness Plans for Electrical Corporations and Regulated Water Companies Pursuant to Public Utilities Code Section Rulemaking (Filed June 11, 2015) JOINT PARTIES FILING OF UPDATED DRAFT STRAW PROPOSAL FOR PHYSICAL SECURITY REGULATIONS I. INTRODUCTION Southern California Edison Company ( SCE ) and the parties listed below submit the attached updated straw proposal in response to the Administrative Law Judge s July 12, 2017 Ruling, as amended by the Administrative Law Judge s ruling of August 24, This proposal is submitted jointly by SCE and by the parties listed below. 1 The attached straw proposal merges the two proposals submitted to the Commission on June 20, 2017, and includes input obtained at workshops led by the California Public Utilities Commission s Safety & Enforcement Division staff ( Commission and SED, respectively). The parties appreciate this opportunity to work on this issue of common interest, and look forward to working collaboratively with the Commission. 1 SCE counsel represents that the parties listed below authorized SCE to join in this filing. 1

3 The following parties join in submitting the proposal: Bear Valley Electric Service California Municipal Utilities Association ( CMUA ) Los Angeles Department of Water & Power ( LADWP ) Liberty CalPeco National Rural Electric Cooperative Association ( NRECA ) PacifiCorp Pacific Gas & Electric Company Sacramento Municipal Utility District ( SMUD ) San Diego Gas & Electric Company Southern California Edison Company II. JURSIDCTIONAL STATEMENT OF THE CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION, LOS ANGELES DEPARTMENT OF WATER & POWER, NATIONAL RURAL ELECTRIC COOPERATIVE ASSOCIATION, AND SACRAMENTO MUNICIPAL UTILITY DISTRICT 2 The legislative mandates included in SB 699 (stats. 2014) and AB 1650 (stats. 2012) are specific to Commission-jurisdictional entities and, as a result, local publicly owned electric utilities ( POUs ) do not fall within the scope of this rulemaking and are not subject to the Commission s enforcement jurisdiction. 3 CMUA members, including SMUD and LADWP, are owners and operators of transmission and distribution facilities located in the State of California and appreciate the importance of the issues raised in the rulemaking. For that reason, CMUA, SMUD, and LADWP are parties to this proceeding, and have participated in the workshops and working groups to develop reasonable industry guidelines based on best practices. CMUA, 2 This Jurisdictional Statement is included in this filing on behalf of CMUA, LADWP, NRECA and SMUD, and as a convenience for the Commission by consolidating initial comments about the Joint Proposal into a single filing. The other parties referenced in Section I of this filing, including the filing party, take no position on the Jurisdictional Statement. 3 See Opening Comments of The Los Angeles Department of Water and Power, dated July 22, 2015, at

4 SMUD, and LADWP object to the Commission s assertion of jurisdiction to impose and enforce rules on the POUs governing the electric transmission and distribution systems of POUs. CMUA, SMUD, and LADWP s participation in this proceeding, including joining the submission of this Straw Proposal, does not waive this jurisdictional issue. Any decision, ruling, or order adopted in this proceeding should be consistent with the legislative mandate set forth in SB 699 and the amendments to Public Utilities Code section 364, as well as AB 1650 and Public Utilities Code Section 768.6, and will not expand or enlarge the Commission s jurisdiction over POUs. Further, the Commission s jurisdiction over Electrical Cooperatives is limited under Public Utilities Code section The Electrical Cooperatives have participated in this proceeding for similar reasons as the POUs and do not concede or waive jurisdiction through their participation in this proceeding. Respectfully submitted, GLORIA ING ROBERT KANG /s/ Robert Kang By: Robert Kang 2244 Walnut Grove Ave. Rosemead, CA Telephone: (626) Facsimile: (626) Robert.Kang@sce.com August 31, 2017 Attorneys for Southern California Edison Company 3

5 ATTACHMENT

6 STRAW PROPOSAL R Proposed Guidelines for Electric Utility Distribution System Security Assessments 1 Purpose PART 1 INTRODUCTION The purpose of these guidelines is to address the physical security risks to the distribution systems of Electrical Corporations, in compliance with Senate Bill 699 (Ch. 550, Hill), as codified at California Public Utilities Code Section Applicability The guidelines contained in this proposal apply to Electrical Corporations subject to the jurisdiction of the California Public Utilities Commission (Commission). These guidelines do not apply to the Local Publicly Owned Electric Utilities and Electrical Cooperatives, however, they represent industry standards that the POUs and electrical cooperatives will use to evaluate and update their current physical security programs, subject to the oversight of their respective governing bodies. These guidelines do not apply to facilities subject to the California Independent System Operator s operational control and/or subject to North American Electric Reliability Corporation (NERC) Reliability Standard CIP or its successors. 3 General This document is intended to implement a risk management approach towards distribution system physical security, with appropriate consideration for the resiliency, impact, and cost. This document reflects the following general principles, as established in the workshops: 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. 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. 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. 1

7 Protecting the distribution system should consider both physical security protection and operational resiliency or redundancy. The focus should not be on all Distribution Facilities, but only those that risk dictates would require additional measures. 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. PART 2 DEFINITIONS Confidential Information: Information that the Commission determines is exempt from the California Public Records Act. Such information may be submitted to the Commission pursuant to Public Utilities Code Sections 364(d) and 583. Covered Distribution Facility: A Distribution Facility, resulting from the process set forth in Part 3. Distribution Control Center: a facility that has responsibility for monitoring and directing operational activity on distribution power lines and Distribution Substations. Distribution Facility: A Distribution Substation or Distribution Control Center. Distribution Substation: an electric power substation associated with the distribution system and the primary feeders for supply to residential, commercial, and/or industrial loads. Electrical Cooperative: as defined in California Public Utilities Code Section Electrical Corporation: as defined in California Public Utilities Code Section 218. Local Publicly Owned Electric Utility: as defined in California Public Utilities Code Section Mitigation Plan: The documentation of a risk-based strategy for mitigating the impacts of a physical attack on a Covered Distribution Facility. The strategy may consist of operational resiliency measures or physical security measures. Operator: an Electrical Corporation, a Local Publicly Owned Electric Utility, or an Electrical Cooperative responsible for the reliability of one or more Distribution Facilities. Public Information: Information that can be made publicly available in accordance with the California Public Records Act and without causing negative impacts to customer and utility safety, security, reliability, privacy and/or economics. 2

8 Reading Room Approach: A method for sharing Security-Sensitive Information with the Commission. Security-Sensitive Information will be available for inspection at the Operator s headquarters, or a mutually agreed-to location, by Commission staff upon request. Security-Sensitive Information: Information that if disclosed could negatively impact public safety or the safe and reliable operation of an Operator s system. Such information may only be shared with Commission staff using enhanced access controls, such as the Reading Room approach. Such information is exempt from the California Public Records Act. 1. Overview PART 3 DISTRIBUTION SUBSTATION & DISTRIBUTION CONTROL CENTER SECURITY PROGRAMS Each Operator will establish a Distribution Substation and Distribution Control Center Security Program (Distribution Security Program). As part of its Program, each Operator will identify which, if any, of its Distribution Facilities meet the criteria set forth in Section 2 of this Part. Next, the Operator, pursuant to Section 3 of this Part, will evaluate the potential risks associated with a physical attack on each of the Distribution Facilities meeting the criteria of Part 3, Section 2, and assess whether existing grid resiliency and/or physical security measures appropriately mitigate the risks. Those identified Distribution Facilities that do not have existing grid resiliency and/or physical security measures necessary to appropriately mitigate the risks will be considered Covered Distribution Facilities. For each of its Covered Distribution Facilities, an Operator will then develop a Mitigation Plan to document the strategy for mitigating the risk and/or consequences of an attack on the Covered Distribution Facility. An unaffiliated third-party will review (1) the process used by Operators to identify the Covered Distribution Facilities and (2) the Mitigation Plan(s) developed by Operators to reduce the risks and/or the consequences of an attack on Covered Distribution Facilities. Each Operator will review each of its Mitigation Plans at least once every five years. 2. Identification Consistent with the general principles in Part 1, Section 3, the following criteria provide Operators with guidance needed to identify Distribution Facilities requiring further assessment: a) 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 3

9 Independent System Operator s (CAISO) operational control and/or subject to North American Electric Reliability Corporation (NERC) Reliability Standard CIP or its successors; b) Distribution Facility that is the primary source of electrical service to a military installation essential to national security and/or emergency response services (may include certain air fields, command centers, weapons stations, emergency supply depots); c) 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); d) 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); e) Distribution Facility that serves a major transportation facility (may include International Airport, Mega Seaport, other air traffic control center, and international border crossing); f) Distribution Facility that serves a Level 1 Trauma Center as designated by the Office of Statewide Health Planning and Development; g) Distribution Facility that serves over 60,000 meters. If an Operator does not identify any Distribution Facilities requiring further assessment, the Operator is not required to conduct the tasks set forth in Part 3, Sections 3, 4, 5 and Assessment Once an Operator has identified its Distribution Facilities that require further assessment taking into account the criteria described in Part 3, Section 2, the Operator will conduct an evaluation of the potential risks associated with a successful physical attack on such Facilities and whether existing grid resiliency, requirements for customer-owned back-up generation and/or physical security measures appropriately mitigate the risks. In conducting this evaluation, the Operator may consider, without limitation, the following factors: 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); The availability of spare assets to restore a particular load; The existing physical security protections to reasonably address the risk; The potential for emergency responders to identify and respond to an attack in a timely manner; Location and physical surroundings, including proximity to gas pipelines and geographical challenges, and impacts of weather; History of criminal activity at the Distribution Facility and in the area. The availability of other sources of energy to serve the load (e.g., customerowned back-up generation or storage solutions); 4

10 The availability of alternative ways to meet the health, safety, or security requirements served by the load (e.g., back up command center or water storage facility). Those Distribution Facilities whose risks are not appropriately mitigated through existing grid resiliency and/or physical security measures are Covered Distribution Facilities subject to the measures set forth in Part 3, Section Mitigation Plan Each Operator will develop and implement a Mitigation Plan to address the potential risks associated with a physical attack on its respective Covered Distribution Facilities. The Operator has discretion to select the specific security measures or resiliency solutions it deems most appropriate for each Covered Distribution Facility. The Mitigation Plan will include consideration of the reasonableness of the cost of any recommended physical security improvements or resiliency solutions. The Operator may also consider local geography and weather, applicable codes (such as the National Electrical Safety Code then in effect), national electrical industry practices, sound engineering judgment, and its own experience. The primary focus of the Mitigation Plan is to specifically address the risk of a long-term outage to a Covered Distribution Facility due to a physical attack. In developing the Mitigation Plans, Operators may use risk-based performance standards to identify the means by which a Covered Distribution Facility s security can be upgraded (e.g., perimeter security, improved monitoring) and its resiliency improved (e.g., timely access to spare equipment, the ability to serve in whole or in part from another facility or circuit, back-up generation or storage). A performance standard specifies the outcome required, but leaves the specific measures to achieve that outcome up to the discretion of the Operator. In contrast to a design standard or a technologybased standard that specifies exactly how to achieve compliance, a performance standard sets a goal, which in this case is to reduce the risk and/or consequences of a successful physical attack on a Covered Distribution Facility, and provides for a variety of solutions to mitigate the risk and/or consequences and achieve the goal. The following are illustrative examples of potential resiliency and security solutions that could be deployed to address identified risks and are not meant to be binding or definitive or to be required for any particular Distribution Facility: Examples of Potential Resiliency Solutions (a) Strategically Located Spares Strategically locate spare equipment to facilitate the repair of a Covered Distribution Facility; (b) Distribution Resiliency Upgrades Adding circuit ties or other facilities to enhance the ability to switch around damaged facilities to facilitate the repair and restoration of service; 5

11 (c) Enhanced Resiliency Response Develop response strategies for temporarily restoring service (e.g., mobile generation/storage, jumper from an adjacent circuit); Examples of Potential Security Solutions 5. Verification (a) Access Measures to limit unauthorized entry or breach of the facility (e.g., fencing, gates, barriers or other security devices); (b) Deterrent Measures to discourage unauthorized entry or breach of the facility (e.g., cameras, lights); (c) Coordination Measures to further collaborate with Law Enforcement as appropriate. Each Operator will select an unaffiliated third party with the appropriate experience needed to review the Identification and Assessment evaluations and the Mitigation Plan(s) performed and developed by said Operator under Part 3, Sections 2, 3, and 4. This review may occur concurrently with or after the development of the Mitigation Plan, pursuant to the Operator s Distribution Security Program. Each Operator will either modify its Mitigation Plan consistent with the recommendation, if any, of the reviewer, or document its reasons for not doing so. Any Operator that has not identified any Distribution Facilities requiring further assessment pursuant to Part 3, Section 2, is not obligated to meet the requirements of this Section Records Electronic or hard copy records of the Operator s Distribution Security Program implementation will include, at a minimum: The Operator s Identification of Distribution Facilities requiring further assessment under Section 2. Each Operator s Assessment of the potential threats and vulnerabilities of a physical attack and whether existing grid resiliency, customer-owned back-up generation and/or physical security measures appropriately mitigate the risks on each of its identified Distribution Facilities under Section 3. Each Operator s Mitigation Plans covering each of its Covered Distribution Facilities under Section 4. The unaffiliated third-party evaluation of the Operator s Identification and Assessment evaluations and Mitigation Plans performed and developed by the Operator under Sections 2, 3, and 4. If applicable, the Operator s documented reasons for not modifying its Mitigation Plans consistent with the unaffiliated third-party s evaluation. Electronic or hard copy records of the Distribution Security Program implementation will be retained for not less than five (5) years. 6

12 Records maintained under this Part are extremely confidential and will be maintained in a secure manner at the Operator s headquarters. The records maintained by Electrical Corporations will be available for inspection at the Electrical Corporations headquarters or San Francisco offices by Commission staff upon request. 7. Timelines and Frequency Any Operator that has identified at least one Distribution Facility requiring further assessment pursuant to Part 3, Section 2 whose risks are not found to be appropriately mitigated after the assessment under Part 3, Section 3, will complete an initial draft of its Mitigation Plan(s), described in Section 4, within eighteen (18) months from the effective date of these guidelines. Where the Operator is required to seek verification pursuant to Part 3, Section 5, the Operator will obtain an unaffiliated, third-party review, described in Part 3, Section 5, within twenty-seven (27) months from the effective date of these guidelines. Each Operator will meet its obligations, described in Sections 4 and 5 within thirty (30) months of the effective date of these guidelines. 8. Cost Recovery At its discretion, the Operator may establish an account to track the expenditures associated with the development and execution of its Distribution Security Program. Electrical Corporations are authorized to file Tier 1 Advice Letters for this purpose. Electrical Cooperatives and Local Publicly Owned Electric Utilities should act in accordance with processes established by a governing or other type of board with the authority to approve such processes, if any. The Electrical Corporations are also authorized to file separate applications or GRC requests for the recovery of costs associated with their respective Distribution Security Programs. Although the Distribution Security Program documents are considered Security-Sensitive Information and cannot be filed as supporting documentation, the Electrical Corporations may file a public version of the unaffiliated third-party review and Commission approval in support of their recovery requests. PART 4 VERIFICATION REVIEW The Commission may review the unaffiliated third-party verification performed pursuant to an Electrical Corporation s Distribution Security Program to determine such verification was performed in accordance with Part 3, Section 5. Because the documents developed as part of a Distribution Security Program are considered to be Security- 7

13 Sensitive Information (described in Part 5), the review would take place at the Electrical Corporation s headquarters or another facility mutually-agreed upon that can be adequately secured for the purpose of sharing Security-Sensitive Information. For Local Publicly Owned Electrical Utilities and Electrical Cooperatives, the governing board of the Local Publicly Owned Electrical Utility or Electrical Cooperative may review or establish a process for review of the third-party verification to determine such verification was performed in accordance with Part 3, Section 5. PART 5 ELECTRICAL CORPORATION INFORMATION SHARING PROTOCOLS There will be three designated sensitivity levels for Electrical Corporation distribution system information and the following information sharing protocols will apply for each respective level: Public Information (defined above): Information that can be made publically available in accordance with the California Public Records Act and without causing negative impacts to customer and utility safety, security, reliability, privacy and/or economics. The Operators propose no additional changes for how this information is transmitted or secured. Confidential Information (defined above): Information that the Commission determines is exempt from the California Public Records Act. Such information may be submitted to the Commission pursuant to Public Utilities Code Sections 364(d) and 583. The Operators propose no additional changes for how this information is transmitted or secured. Security-Sensitive Information (defined above): Information that is exempt from the California Public Records Act, and which may be shared with Commission staff only using enhanced secure access control measures, such as the Reading Room approach. Disclosure of Security-Sensitive Information could negatively impact public safety or the safe and reliable operation of an Operator s system, and will be shared only when using heightened security controls beyond Public Utilities Code Section 583. The definition of Security-Sensitive Information and proposal for how it is transmitted and secured was developed as a direct result of security expert panel discussions, Operator and stakeholder presentations, as well as input and comments from the CPUC. 8

14 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 Corporations Consistent with Public Utilities Code Section 364 and to Establish Standards for Disaster and Emergency Preparedness Plans for Electrical Corporations and Regulated Water Companies Pursuant to Public Utilities Code Section Rulemaking (Filed June 11, 2015) CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of the JOINT PARTIES FILING OF UPDATED DRAFT STRAW PROPOSAL FOR PHYSICAL SECURITY REGULATIONS on all parties identified on the attached service list(s) R Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Gerald F. Kelly CPUC 505 Van Ness Avenue San Francisco, CA Executed this August 31, 2017, at Rosemead, California. /s/ Jorge Martinez Jorge Martinez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California

15 CPUC - Service Lists - R Page 1 of 7 8/31/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR FOR REGUL FILER: CPUC LIST NAME: LIST LAST CHANGED: AUGUST 30, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties BRIAN STEWART JAY MORRISON DEPUTY CITY ATTORNEY V.P.- REGULATORY AFFAIRS LOS ANGELES DEPT. OF WATER & POWER NATIONAL RURAL ELECTRIC COOP. ASSN WILSON BOULEVARD, FLOOR 11, CA ARLINGTON, VA FOR: LOS ANGELELS DEPARTMENT OF WATER FOR: NATIONAL RURAL ELECTRIC AND POWER COOPERATIVE ASSOCIATION ROBERT J. KANG KEITH MELVILLE SR. ATTY SR. COUNSEL SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTIRIC COMPANY 2244 WALNUT GROVE AVE., PO BOX CENTURY PARK CT., CP-32D ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY RASHID A. RASHID LEGAL DIVISION ROOM 5131 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE WILLIAM MAGUIRE LEGAL DIVISION SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SED FOR: ORA STEPHEN GARBER MARTIN A. MATTES ATTORNEY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY NOSSAMAN LLP 77 BEALE STREET, RM CALIFORNIA STREET, 34TH FL. SAN FRANCISCO, CA SAN FRANCISCO, CA 94111

16 CPUC - Service Lists - R Page 2 of 7 8/31/2017 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CALIFORNIA WATER ASSOCIATION VIDHYA PRABHAKARAN MELISSA W. KASNITZ ATTORNEY CENTER FOR ACCESSIBLE TECHNOLOGY DAVIS WRIGHT & TREMAINE LLP 3075 ADELINE STREET, STE MONTGOMERY STREET, SUITE 800 BERKELEY, CA SAN FRANCISCO, CA FOR: CENTER FOR ACCESSIBLE TECHNOLOGY FOR: LIBERTY UTILITIES (LIBERTY CALPECO) (CFORAT) JUSTIN WYNNE JEDEDIAH J. GIBSON ATTORNEY ATTORNEY AT LAW BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. ELLISON SCHNEIDER HARRIS & DONLAN LLP 915 L STREET, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA MUNICIPAL UTILITIES FOR: BEAR VALLEY ELECTRIC SERVICE / ASSOCIATION (CMUA) CALIFORNIA ASSOCIATION OF SMALL AND MULTI-JURISDICTIONAL UTILITIES JOY MASTACHE CATHIE ALLEN SR. ATTY - OFF. OF GEN. COUNSEL REGULATORY AFFAIRS MGR. SACRAMENTO MUNICIPAL UTILITY DISTRICT PACIFICORP 6301 S STREET, MS A NE MULTNOMAH ST., STE 2000 SACRAMENTO, CA PORTLAND, OR FOR: SACRAMENTO MUNICIPAL UTILITY FOR: PACIFICORP DISTRICT (SMUD) Information Only BRADLEY CARTER CASE COORDINATION PROJECT MGR. PACIFIC GAS AND ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY, CA 00000, CA KATIE JORRIE LINH DOAN DAVIS WRIGHT TREMAINE, LLP LOS ANGELES DEPT. OF WATER & POWER, CA 00000, CA PATRICK FERGUSON PJOY CHUA ATTORNEY MGR - REGULATORY STDS AND COMPLIANCE DAVIS WRIGHT TREMAINE, LLP LOS ANGLES DEPT OF WATER AND POWER O NLY, CA ONL Y, CA ROBERT A. LAURIE SANGEETHA LOSARI ASSISTANT GENERAL COUNSEL - ENERGY LOS ANGELES DEPT OF WATER & POWER IMPERIAL IRRIGATION DISTRICT, CA 00000, CA MRW & ASSOCIATES, LLC DAVIS WRIGHT TREMAINE LLP

17 CPUC - Service Lists - R Page 3 of 7 8/31/2017, CA 00000, CA LISA S. GAST BARRY R. LAWSON DUNCA WEINBERG GENZER & PEMBROKE, P.C. ASSOC. DIR.- GOVERNMENT RELATIONS 1615 M STREET, N. W., SUITE 800 NATIONAL RURAL ELETRIC COOPERATIVE ASSN. WASHINGTON, DC WILSON BLVD., MC GR ARLINGTON, VA PAUL M. BREAKMAN, ESQ LOUIS TING FERC COUNSEL CHIEF COMPLIANCE OFFICER NATIONAL RURAL ELECTRIC COOP. ASSN. LOS ANGELES DEPT. OF WATER & POWER 4301 WILSON BLVD., FLOOR N.HOPE STREET, SUITE 921 ARLINGTON, VA LOS ANGELES, CA FOR: LOS ANGELES DEPARTMENT OF WATER & POWER (LADWP) DANIEL W. MARSH EDWARD JACKSON MGR - RATES & REGULATORY AFFAIRS DIR - REVENUE REQUIREMENTS LIBERTY UTILITIES (CALIFORNIA) LIBERTY UTILITIES (CALIFORNIA) 9750 WASHBURN ROAD 9750 WASHBURN ROAD / PO BOX 7002 DOWNEY, CA DOWNEY, CA JOSEPH PARK FRED YANNEY DIRECTOR OF LEGAL SERVICES MARQUARDT AVE., UNIT C-4 LIBERTY UTILITIES (CALIFORNIA) CERRITOS, CA WASHBURN ROAD DOWNEY, CA DANIEL W. DOUGLASS GLORIA ING ATTORNEY ATTORNEY AT LAW DOUGLASS & LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY 4766 PARK GRANADA, SUITE WALNUT GROVE AVE./ PO BOX 800 CALABASAS, CA ROSEMEAD, CA FOR: WESTERN POWER TRADING FORUM (WPTF) FOR: SOUTHERN CALIFORNIA EDISON COMPANY KAREN CHUNG NGUYEN QUAN MGR - PROJECT REGULATORY AFFAIRS SOUTHERN CALIFORNIA EDISON COMPANY BEAR VALLEY ELECTRIC SERVICE 2244 WALNUT GROVE AVENUE 630 EAST FOOTHILL BLVD. ROSEMEAD, CA SAN DIMAS, CA FOR: BEAR VALLEY ELECTRIC SERVICE CASE ADMINISTRATION DONALD C. LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY ATTORNEY 8631 RUSH STREET DOUGLASS & LIDDELL ROSEMEAD, CA ND AVENUE SAN DIEGO, CA SHIVANI N. BALLESTEROS CENTRAL FILES REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP31F SAN DIEGO, CA SAN DIEGO, CA 92123

18 CPUC - Service Lists - R Page 4 of 7 8/31/2017 PAUL MARCONI DIABLO CANYON INDEPENDENT SAFETY COMM. BEAR VALLEY ELECTRIC SERVICE 857 CASS STREET, SUITE D GARSTIN DRIVE, PO BOX 1547 MONTEREY, CA BIG BEAR LAKE, CA MARC D JOSEPH MARC D. JOSEPH ADAMS BROADWELL JOSEPH & CARDOZO, PC ATTORNEY AT LAW 601 GATEWAY BLVD., STE ADAMS BROADWELL JOSEPH & CARDOZO SOUTH SAN FRANCISCO, CA GATEWAY BLVD. STE 1000 SOUTH SAN FRANCISCO, CA JOHN K. HAWKS KATY MORSONY CALIFORNIA WATER ASSOCIATION ALCANTAR & KAHL LLP 601 VAN NESS AVE., STE. 2047, MC E CALIFORNIA STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA AICHI N. DANIEL ALICE L. REID ATTORNEY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 777 BEALE STREET B30A 77 BEALE STREET, RM 3081-B30A SAN FRANCISCO, CA SAN FRANCISCO, CA JOE LOYA CALIFORNIA COASTAL COMMISSION PACIFIC GAS AND ELECTRIC COMPANY 45 FREMONT ST., STE BEALE ST., RM MAIL CODE B10C SAN FRANCISCO, CA SAN FRANCISCO, CA BRIAN CRAGG MARI R. DAVIDSON, ESQ. ATTORNEY NOSSAMAN LLP GOODIN, MACBRIDE, SQUERI & DAY, LLP 50 CALIFORNIA STREET, 34TH FLOOR 505 SANSOME ST., STE. 900 SAN FRANCISCO, CA SAN FRANCISCO, CA EMILY P. SANGI CALIFORNIA ENERGY MARKETS ATTORNEY 425 DIVISADERO ST STE 303 DAVIS WRIGHT TREMAINE LLP SAN FRANCISCO, CA MONTGOMERY ST., STE. 800 SAN FRANCISOC, CA IGOR GRINBERG AVIS KOWALEWSKI PACIFIC GAS AND ELECTRIC COMPANY VP - GOV'T & REGULATORY AFFAIRS REGULATORY AFFAIRS CALPINE CORPORATION 77 BEALE ST., MC B10B / PO BOX DUBLIN BLVD, SUITE 100 SAN FRANCISCO, CA DUBLIN, CA KATHERINE C. PIPER STEPHEN B. BOWEN CALPINE COPORATION BOWEN LAW GROUP 4160 DUBLIN BLVD., STE SCARBOROUGH DR., STE. 201 DUBLIN, CA OAKLAND, CA NATALIE D. WALES INTERIM DIR. - REGULATORY MATTERS C. SUSIE BERLIN LAW OFFICES OF C. SUSIE BERLIN

19 CPUC - Service Lists - R Page 5 of 7 8/31/2017 CALIFORNIA WATER SERVICE COMPANY 1346 THE ALAMEDA, SUITE 7, NO NORTH FIRST STREET SAN JOSE, CA SAN JOSE, CA STEPHEN R. CIESLEWICZ JORDAN PINJUV CN UTILITY CONSULTING, INC COUNSEL 120 PLEASANT HILL AVE. NORTH, STE.190 CALIFORNIA INDEPENDENT SYSTEM OPERATOR SEBASTOPOL, CA OUTCROPPING WAY FOLSOM, CA LEGAL DEPARTMENT DAN GRIFFITHS CALIFORNIA ISO ATTORNEY 250 OUTCROPPING WAY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. FOLSOM, CA L STREET, SUITE 1480 SACRAMENTO, CA SEAN M. NEAL CALIFORNIA BUILDING INDUSTRY ASSOCIATION DUNCAN WEINBERG GENZER & PEMBROKE, P.C NINTH STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: NATIONAL RURAL ELECTRIC COOPERATIVE ASSOCIATION (NRECA) JEROME CANDELARIA ANDREW B. BROWN ASSISTANT GENERAL COUNSEL ATTORNEY AT LAW CALIFORNIA CABLE TV ASSOCIATION ELLISON SCHNEIDER & HARRIS LLP 1001 K STREET, 2ND FLOOR 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA ANN L. TROWBRIDGE CYNTHIA HANSEN MIFSUD ATTORNEY AT LAW SR ATTORNEY DAY CARTER & MURPHY LLP PACIFICORP 3620 AMERICAN RIVER DRIVE, SUITE NE MULTNOMAH, SUITE 1800 SACRAMENTO, CA PORTLAND, OR HEIDEMARIE C. CASWELL JACK VRANISH DIRECTOR-TRANSMISSION & DIST. ASSET PERF PACIFICORP PACIFICORP 825 NE MULTNOMAH, STE NE MULTNOMAH, SUITE 1500 PORTLAND, OR PORTLAND, OR State Service CHRIS UNGSON CPUC - ORA, CA FADI DAYE PROGRAM & PROJECT SUPERVISOR - SED CALIFORNIA PUBLIC UTILITIES COMMISSION, CA HAL KANE SR. ANALYST, RISK ASSESSMENT CPUC - SED DIV NILS STANNIK ORA CALIFORNIA PUBLIC UTILITIES COMMISSION

20 CPUC - Service Lists - R Page 6 of 7 8/31/2017, CA 00000, CA RYAN T. YAMAMOTO TONY MARINO CALIF . PUBLIC UTILITIES COMMISSION OFFICE OF SENATOR JERRY HILL, CA 00000, CA WINNIE HO ARTHUR J. O'DONNELL ELECTRIC SAFETY AND RELIABILITY BRANCH RISK ASSESSMENT AND ENFORCEMENT 320 West 4th Street Suite 500 AREA Los Angeles, CA VAN NESS AVENUE SAN FRANCISCO, CA CAMERON REED CAROLINA CONTRERAS COMMUNICATIONS AND WATER POLICY BRANCH OFFICE OF THE SAFETY ADVOCATE AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: OSA CHARLOTTE TERKEURST CHLOE LUKINS ELECTRIC SAFETY AND RELIABILITY BRANCH ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA CHRISTOPHER PARKES DAVID PECK OFFICE OF THE SAFETY ADVOCATE PRESIDENT PICKER AREA 2-D ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA GERALD F. KELLY JEREMY BATTIS DIVISION OF ADMINISTRATIVE LAW JUDGES RISK ASSESSMENT AND ENFORCEMENT ROOM 5011 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JUNAID RAHMAN MARTIN KURTOVICH RISK ASSESSMENT AND ENFORCEMENT RISK ASSESSMENT AND ENFORCEMENT AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHANIEL SKINNER ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA 4-A NILS STANNIK ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA

21 CPUC - Service Lists - R Page 7 of 7 8/31/ VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA QUANG PHAM RAYMOND CHO COMMUNICATIONS AND WATER POLICY BRANCH ELECTRIC SAFETY AND RELIABILITY BRANCH AREA 2-D AREA 2-D 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TRAVIS FOSS COMMISSIONER RECHTSCHAFFEN ROOM VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

22 CALIFORNIACOASTALCOMMISSION 45FREMONTSTREET,SUITE2000 SANFRANCISCO,CA94105 List of Non- Recipients CALIFORNIABUILDINGINDUSTRY ASSOCIATION 1107NINTHSTREET,SUITE1060 SACRAMENTO,CA95814