BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) )

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E COMMENTS ON ADMINISTRATIVE LAW JUDGE S RULING SEEKING COMMENTS ON THE RELIABILITY REPORT TEMPLATE FRANK A. MCNULTY KRIS G. VYAS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( mcnultfa@sce.com Dated: September 10, 2015 LIMS

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E COMMENTS ON ADMINISTRATIVE LAW JUDGE S RULING SEEKING COMMENTS ON THE RELIABILITY REPORT TEMPLATE I. INTRODUCTION Pursuant to the ADMINISTRATIVE LAW JUDGE S RULING SEEKING COMMENTS ON THE RELIABILITY REPORT TEMPLATE (Ruling, dated August 31, 2015, and the California Public Utilties Commission (Commission Rules of Practice and Procedure, Southern California Edison Company (SCE respectfully submits these comments. II. RESPONSE The Ruling solicits parties comments on a proposed template, or table of contents, the respondent utilities are to use for future reliability reporting. This template generally reflects discussions among participants at the Commission-sponsored workshops in this proceeding. For the most part, SCE agrees that the report template accurately reflects the workshop discussions and supports Commission adoption of that template. Below SCE provides its comments on certain items in the template that should be revised. 1

3 A. Section 3 Of The Template Would Require Reporting Reliability Metrics For The Last 10 Years, A Requirement Not Discussed At The Workshop And That SCE Does Not Have Section 3 of the template is entitled SYSTEM INDICES FOR THE LAST 10 YEARS BASED ON IEEE 1366 AND INCLUDING PLANNED OUTAGES. SCE does not calculate the standard reliability indices (SAIDI, SAIFI, MAIFI and CAIDI for planned outages, so does not have that data for the past 10 years and could not comply with this requirement. Further, modifying current reliability reporting to include those indices for planned outages was not discussed during the workshops. These comments are the first opportunity for utilities to address this proposal. SCE therefore asks the Commission to revise the proposed template to remove the requirement that utilities report 10 years of recorded reliability metrics for planned outages. B. Section 10 Of The Template, Which Would Require Reporting On Steps Taken To Protect Critical Reliability Information From Cyber Threats, Should Be Stayed Pending Resolution Of R Section 10 of the template is entitled DEMONSTRATION OF STEPS TAKEN TO PROTECT CRITICAL RELIABILITY INFORMATION FROM CYBER THREATS. This issue was not vetted during the workshops in this proceeding. However, on June 22, 2015, the Commission instituted R , which is considering what policies, procedures, and rules it should adopt regarding physical security of electric utilities. 1 Appendix B to that Rulemaking contains a report prepared by Commission staff, which notes: It is impossible to completely separate physical security from cyber and information security. 2 Since cyber security issues are specifically within the scope of R and were not addressed in the workshops in the instant rulemaking, SCE requests that Item 10 of the template be stayed pending completion of Phase 1 of R , which is to address physical security issues. 1 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 R , Appendix B, p. iv. 2

4 III. CONCLUSION SCE appreciates this opportunity to submit its comments on the ALJ s Ruling and asks that the reporting requirements be clarified or modified as discussed herein. Respectfully submitted, FRANK A. MCNULTY KRIS G. VYAS /s/ FRANK A. MCNULTY By: Frank A. McNulty Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( mcnultfa@sce.com September 10,

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 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 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E COMMENTS ON ADMINISTRATIVE LAW JUDGE S RULING SEEKING COMMENTS ON THE RELIABILITY REPORT TEMPLATE on all parties identified on the attached service list 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. David M. Gamson Commissioner Michael Picker Hazlyn Fortune CPUC CPUC 505 Van Ness Avenue 505 Van Ness Ave. San Francisco, CA San Francisco, CA Executed September 10, 2015, at Rosemead, California. /s/ Laura Velarde Laura Velarde Executive Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

6 CPUC - Service Lists - R Page 1 of 4 9/10/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR REGARDING FILER: CPUC LIST NAME: LIST LAST CHANGED: AUGUST 31, 2015 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JAMIE L MAULDIN QUINN M. BARROW ADAMS BROADWELL JOSEPH & CARDOZO CITY ATTORNEY CITY OF MANHATTAN BEACH, CA HIGHLAND AVE. FOR: COALITION OF CALIFORNIA UTILITY MANHATTAN BEACH, CA EMPLOYEES (CCUE FOR: CITY OF MANHATTAN BEACH JACKI BACHARACH LEROY J. JACKSON EXECUTIVE DIRECTOR CITY MANAGER SOUTH BAY CITITES COUNCIL OF GOVERNMENTS CITY OF TORRANCE S. WESTERN AVE., SUITE TORRANCE BLVD., 3RD FLOOR TORRANCE, CA TORRANCE, CA FOR: SOUTH BAY CITIES COUNCIL OF FOR: CITY OF TORRANCE GOVERNMENTS (SBCCG FRANCIS MCNULTY NGUYEN QUAN BEAR VALLEY ELECTRIC SERVICE SOUTHERN CALIFORNIA EDISON COMPANY 630 EAST FOOTHILL BLVD WALNUT GROVE AVENUE, ROOM 370 SAND IMAS, CA ROSEMEAD, CA FOR: BEAR VALLEY ELECTRIC SERVICE (A FOR: SOUTHERN CALIFORNNIA EDISON COMPANY DIVISION ON GOLDEN STATE WATER SERVICE CO. KEITH W. MELVILLE CLEVELAND LEE SR. COUNSEL SAN DIEGO GAS & ELECTRIC COMPANY LEGAL DIVISION 8330 CENTURY PARK CT., CP32 ROOM 5122 SAN DIEGO, CA VAN NESS AVENUE FOR: SAN DIEGO GAS & ELECTRIC COMPANY SAN FRANCISCO, CA FOR: ORA ELISE TORRES EVELYN KAHL STAFF ATTORNEY THE UTILITY REFORM NETWORK ALCANTAR & KAHL, LLP 785 MARKET STREET, SUITE NEW MONTGOMERY ST., STE. 1850

7 CPUC - Service Lists - R Page 2 of 4 9/10/2015 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ENERGY PRODUCERS AND USERS COALITION (EPUC STEPHEN L. GARBER VIDHYA PRABHAKARAN DAVIS WRIGHT & TREMAINE LLP PACIFIC GAS AND ELECTRIC COMPANY 505 MONTGOMERY STREET, SUITE BEALE STREET; MCB30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: LIBERTY UTILITIES (FORMERLY FOR: PACIFIC GAS AND ELECTRIC COMPANY CALPECO ELECTRIC LLC MICHELLE R. MISHOE SR. COUNSEL PACIFICORP 825 NE MULTNOMAH ST., STE 1800 PORTLAND, OR FOR: PACIFICORP Information Only ALANA VOLSKAYA BARBARA H. CLEMENT PACIFIC GAS AND ELECTRIC COMPANY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA BRUCE SMITH CASE ADMINISTRATION PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA DAVID MARCUS EMILY SANGI ADAMS BROADWELL & JOSEPH DAVIS WRIGHT TREMAINE, CA 00000, CA KATY MORSONY MARC D. JOSEPH ALCANTAR & KAHL ADAMS BROADWELL JOSEPH & CARDOZO, CA 00000, CA RACHEL GOLD UDI HELMAN POLICY DIRECTOR HELMAN ANALYTICS LARGE-SCALE SOLAR ASSOCIATION, CA 00000, CA MRW & ASSOCIATES, LLC KAREN TERRANOVA ALCANTAR & KAHL, CA 00000, CA DAVIS WRIGHT TREMAINE, LLC LENA LUNA SO. BAY CITIES COUNCIL OF GOVERNMENTS, CA S. WESTERN AVE., STE. 100 TORRANCE, CA CASE ADMINISTRATION MICHAEL MOORE SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE / PO BOX WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA JOSEPH MCCAWLEY REBECCA W. GILES SAN DIEGO GAS & ELECTRIC COMPANY REGULATORY CASE MANAGER 8316 CENTURY PARK COURT SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK COURT, CP32-D SAN DIEGO, CA CENTRAL FILES SUE MARA SAN DIEGO GAS & ELECTRIC COMPANY CONSULTANT 8330 CENTURY PARK CT, CP31-E RTO ADVISORS, LLC SAN DIEGO, CA SPRINGDALE WAY REDWOOD CITY, CA 94062

8 CPUC - Service Lists - R Page 3 of 4 9/10/2015 DAVID K. LEE CALIFORNIA ENERGY MARKETS 425 DIVISADERO ST. SUTIE 303 INFRASTRUCTURE PLANNING AND PERMITTING B SAN FRANCISCO, CA AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA MEGAN M. MYERS SARA STECK MYERS ATTORNEY LAW OFFICES OF SARA STECK MYERS LAW OFFICES OF SARA STECK MYERS TH AVENUE TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA PHILLIP MULLER JAMES H. CALDWELL, JR. PRESIDENT 1650 E. MAPA STREET SCD ENERGY SOLUTIONS SONOMA, CA NOVA ALBION WAY SAN RAFAEL, CA SCOTT BLAISING ANDREW B. BROWN ATTORNEY ELLISON SCHNEIDER & HARRIS L.L.P. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C CAPITOL AVENUE, STE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA CHRISTA LIM RONALD LIEBERT ELLISON SCHNEIDER & HARRIS, LLP 2600 CAPITOL AVENUE, SUITE 400 ELLISON SCHNEIDER & HARRIS LLP SACRAMENTO, CA CAPITOL AVENUE, STE. 400 SACRAMENTO, CA JEDEDIAH J. GIBSON JEFFREY D. HARRIS ELLISON SCHNEIDER & HARRIS LLP ELLISON, SCHNEIDER & HARRIS LLP 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA LYNN M. HAUG CATHIE ALLEN ELLISON, SCHNEIDER & HARRIS LLP REGULATORY AFFAIRS MGR CAPITOL AVENUE, SUITE 400 PACIFICORP SACRMENTO, CA NE MULTNOMAH ST., STE 2000 PORTLAND, OR HEIDE CASWELL PACIFICORP 825 NE MULTNOMAH, STE PORTLAND, OR State Service HAZLYN FORTUNE RYAN YAMAMOTO ALJ PRO TEM CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA VALERIE KAO DAVID M. GAMSON SED CALIFORNIA PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5019, CA VAN NESS AVENUE FOR: SED SAN FRANCISCO, CA GABRIEL PETLIN JOHN D. ERICKSON INFRASTRUCTURE PLANNING AND PERMITTING B INFRASTRUCTURE PLANNING AND PERMITTING B AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA OGEONYE ENYINWA

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