ANAHEIM PUBLIC U TILITIES
PHYSICAL SECURITY PLAN
2026 UPDATE
June 2026
2 TABLE OF CONTENTS
A. Executive Summary ....................................................................................................................... 3 B. Goal of APU Physical Security Plan .............................................................................................. 4 C. Description of APU ......................................................................................................................... 4 D. Results of APU Physical Security Plan Assessment ...................................................................... 5 I. Background .......................................................................................................................................... 5 II. Plan Development Process ................................................................................................................ 7 A. Physical Security Principles............................................................................................................ 7 B. APU Physical Security Plan Development Process ..................................................................... 7 Step 1: Assessment/Plan Development ............................................................................................ 7 Step 1A: Identify Covered Distribution Facilities ............................................................................... 8 Step 1B: Perform Risk Assessment ....................................................................................................... 8 Step 1C: Develop Mitigation Plan ..................................................................................................... 8 Step 2: Independent Review ............................................................................................................. 8 Step 3: Validation ................................................................................................................................ 9 Step 4: Adoption .................................................................................................................................. 9 Step 5: Maintenance .......................................................................................................................... 9 Step 6: Repeat Process ....................................................................................................................... 9 III. Identification Of Covered Distribution Facilities (Step 1A) ............................................................. 9 A. Identification Factors ..................................................................................................................... 9 B. Identification Analysis .................................................................................................................. 10 IV. Risk Assessment (Step 1B).................................................................................................................. 13 A. Methodology ................................................................................................................................ 13 B. Mitigation Measures .................................................................................................................... 13 C. Risk Assessment ............................................................................................................................ 14 V. Covered Distribution Facility Mitigation Plans (Step 1C) ............................................................... 17 VI. Independent Evaluation and Response (Step 2) .......................................................................... 18 A. Requirements for Qualified Third-Party Review ........................................................................ 18 B. Identification of Third-Party Reviewer ........................................................................................ 18 C. Public Results of Third-Party Evaluation ..................................................................................... 18 D. APU Implementation of Third-Party Recommendation .......................................................... 20 VII. Validation (Step 3) ............................................................................................................................. 20 A. Selection of Qualified Authority ................................................................................................. 20 B. Results of Qualified Authority Review ........................................................................................ 21 VIII. Narrative Descriptions for APU Physical Security Plan ................................................................... 21 A. Asset Management Program ..................................................................................................... 21 B. Workforce Training and Retention Program ............................................................................. 21 C. Preventative Maintenance Plan ................................................................................................ 22
3 A. EXECUTIVE SUMMARY
As consistent with the Joint IOU/POU Straw Proposal and D.19-01-018, Anaheim Public Utilities (APU) has reviewed and updated APU’s Physical Security Plan that was first submitted to the California Public Utilities Commission (CPUC) in July 2021, and as discussed in detail in the following sections of this report.
APU repeated the six-step development process and thoroughly performed the identification and risk assessments, respectively.
As the result of the assessments, APU has determined that there were no changed circumstances that resulted in new Covered Distribution Facilities as compared to 2021. The Metro Cities Fire Authority (also known as Metro Net Fire Dispatch) is a 911 dispatch communications center for several Orange County cities and was previously identified, remains located in Anaheim and is served by APU. Substation “A” identified as a Covered Distribution Facility continues to reliably serve the Metro Net Fire Dispatch.
During the past five years, APU has actively and continually implemented several physical security improvements surrounding its distribution substations and other facilities. Improvements include replacing chain-link fences with solid walls. Other advanced security measures implemented include security cameras, monitoring devices, lights and sirens, radar sensors, and access controls. These physical and electronic improvements are part of APU’s ongoing effort in securing its electrical infrastructures from any potential physical risks. Below is a summary of specific improvements during the past five years, and expected security enhancements in the near future:
a. Replacement of chain-link fences with solid walls around three distribution substations
b. Improvement of communication at multiple substations o Monitoring communication and discovery of Information Technology (IT) and Operation Technology (OT) assets
o Analysis of communication patterns
o Alerts for suspicious communication patterns
o Assignment of asset risk rating to identify systems that require immediate attention
o Disabled unused network ports
4 c. Future security enhancements are planned, but not limited to:
o Cameras
o Strobe Lights and Sirens
o Talk Down Speaker
o Radar Sensors
o Access Control (Controllers/Readers)
B. GOAL OF APU PHYSICAL SECURITY PLAN
Ensuring the safety of its facilities is a top priority for APU, and APU prioritizes safety in all aspects of its design, operation, and maintenance practices. The overarching goal of APU’s Physical Security Plan is to describe APU’s risk management approach to distribution system physical security, with appropriate consideration of resiliency, impact, and cost.
APU recognizes the importance of securing the safety and reliability of its electric system and, therefore, APU 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, APU offers the following in response to CPUC Decision 19-01-018.
C. DESCRIPTION OF APU
APU is governed by the Anaheim City Council that includes a mayor elected at- large, and Council Members elected in 6 Council Districts, and is overseen by an appointed 7-member Public Utilities Board. APU is Orange County's only customer-owned, not-for-profit water and power utility serving the City of Anaheim. The APU provides reliable electric and water services to approximately 350,000 residents or 123,000 residential, commercial, and industrial electric customers in Anaheim with over 50 square miles of mostly urban service territory.
APU delivers a customer‐focused approach to providing reliable, high-quality power at competitive rates.
APU is a Participating Transmission Owner (PTO) with the California Independent System Operator (CAISO) as a part owner of shared transmission lines. The distribution system is interconnected to the regional grid at 220 kilovolts (kV). In addition to two transmission voltage substations, APU operates and maintains thirteen (13) 69/12 kV distribution voltage substations and over 120 distribution circuits. In 1990, the Anaheim City Council authorized an Underground
5 Conversion Program to underground existing overhead lines along major thoroughfares, and in 2016 amended the program to expand the types of eligible projects that include reliability improvements such as wildfire safety and security. To date, approximately 143 circuit miles have been undergrounded through this program. In total, inclusive of previously developed underground infrastructure, 860 circuit miles or 68% of APU’s distribution system is underground.
APU features the first fully underground substation in the United States that provides reliability, aesthetic, and operational benefits to the community. APU has ownership rights or purchases wholesale energy from power plants in the Western United States, as well as operates and maintains a gas turbine power plant capable of producing 200 MW of power within its service territory.
D. RESULTS OF APU PHYSICAL SECURITY PLAN ASSESSMENT
APU has reviewed and completed the physical security assessment based on the procedure described below in Section II-B to determine how many distribution substations are Covered Distribution Facilities. All thirteen distribution substations and 220/69kV Substation “M” were evaluated. Based on the assessment it was determined that APU has one Covered Distribution Facility 1, 69/12 kV Substation
“A.” Detailed responses and explanations are provided in Section III-B Identification Analysis.
This Plan was independently reviewed by NV5, as a third-party reviewer, and subsequently reviewed and validated by the Anaheim Police Department (APD), which serves as a qualified authority. The conclusion of APD’s review was that APU’s 2026 Physical Security Plan is deemed to be adequate.
I. 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.
1 Covered Distribution Facility is a distribution facility that requires further risk assessment as outlined in Section II.B.
6 At the state level, Senate Bill (SB) 699 was approved in 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 physical security plans that would identify security risks to their distribution and transmission systems and propose methods to mitigate those risks.
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 in 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 Proposal (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, APU staff participated in the development of the Joint IOU/POU Straw Proposal through a CMUA working group. 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 response to the Joint IOU/POU Straw Proposal that recommended various modifications and clarifications, including a six-step process.
In early 2019, the CPUC approved Decision (D.) 19-01-018 (also referred to in this Plan as the “CPUC Decision” or the “Decision”), which adopted the Joint IOU/POU Straw Proposal as modified by the RASA proposal (jointly referred to as the “Joint 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.
D.19-01-018 asserted that the POUs should utilize the Physical Security Plan process.
APU is following the process and issuing this report to reflect its existing commitment to safety and to protect its ratepayers’ investment by taking reasonable and cost- effective measures to safeguard key assets of its distribution system.
7 II. PLAN DEVELOPMENT PROCESS
A. PHYSICAL SECURITY PRIN CIPLES
The Joint Proposal seeks to support the creation of a risk management approach toward distribution system physical security, with appropriate considerations of resiliency, impact, and cost. To accomplish this risk-based approach, the Joint 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 2, but only those that
require additional measures necessary to address risk.
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. APU PHYSICAL SECURITY PLAN DEVELOPMENT PROCESS
APU utilized a multi-step process to develop its Physical Security Plan that is consistent with the Joint Proposal and D.19-01-018. The relevant six steps of that process are as follows:
STEP 1: ASSESSMENT/PLAN DEVELOPMENT
APU prepared a Draft APU Physical Security Plan through the process set forth in Steps 1A, 1B, and 1C.
2 Distribution Facilities are defined as distribution substations that serve critical loads as listed in Section III.A.
8 STE P 1A: IDENTIFY COVERED DISTRIBUTION FACILITIES
APU evaluated 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 using the seven factors identified in the Joint Proposal.
STEP 1B: PERFORM RISK ASSESSMENT
For every individual Covered Distribution Facility identified pursuant to Step 1A, APU would 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 were 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 APU would develop a Mitigation Plan3 for that Covered Distribution Facility. The Mitigation Plan would 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 APU Physical Security Plan cycle4, APU will document the results of the identification process, risk assessment, and Mitigation Plan development pursuant to Steps 1A, 1B, and 1C. This documentation, in combination with the narrative description in Section IX below, constitutes APU’s Draft Physical Security Plan. Each Draft APU Physical Security Plan is to be submitted to a Qualified Third Party for Independent Review. The Qualified Third-Party Reviewer3 will then issue an evaluation that identifies any potential deficiencies in the Draft APU Physical Security Plan as well as recommendations for improvements. APU will then modify its draft plan to address any identified deficiencies and recommendations or will document the reasons why any recommendations were not adopted. The combination of the Draft APU Physical Security Plan, the non-confidential
3 The documentation of a risk-based strategy for mitigating the impacts of a physical attack on a Covered Distribution Facility. 4 A utility would be required to have any revised or original plan updated and repeat the review process every five years.
9 conclusions of the Qualified Third-Party Reviewer5, and APU’s responses to the Qualified Third-Party Reviewer will constitute the APU Physical Security Plan.
STEP 3: VALIDATION
APU will submit its Physical Security Plan to Anaheim Police Department (APD) for further review and validation. APD will provide additional feedback and evaluation of APU’s Physical Security Plan, until it deems the APU Physical Security Plan as adequate.
STEP 4: ADOPTION
APU’s Physical Security Plan will be presented to and adopted by Anaheim’s City Council at a public meeting.
STEP 5: MAINTENANCE
APU will refine and update its Physical Security Plan as appropriate and as necessary to preserve the plan integrity.
STEP 6: REPEAT PROCESS
APU will repeat this six-step process at least once every five years.
III. IDENTIFICATION OF COVERED DISTRIBUTION FACILITIES (STEP 1A) Step 1A of the APU Physical Security Plan process involves assessing all distribution-level facilities that are subject to APU control to determine which facilities are Covered Distribution Facilities subject to the need for a risk assessment. This section describes the factors that APU used to evaluate its distribution facilities and the results of its evaluation.
A. IDENTIFICATION FACTORS
The Joint Proposal defines seven screening factors to determine if a facility is a Covered Distribution Facility. Some factors required additional definitions and/or clarifications to be applied to APU’s facilities, which POUs collectively developed through the CMUA working group as described further below. The following table provides the Joint Proposal’s Factors pursuant to D. 19-01-018 Section 4.1.
5 A Qualified Third-Party Reviewer is defined as an unaffiliated independent entity not under the control of the utility and with appropriate physical security experience.
10 Factor Joint Proposal Description
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
2 Distribution Facility is the primary source of electrical service to a military installation essential to national security and/or emergency response services (may include certain airfields, command centers, weapon stations, emergency supply depots)
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)
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) 5 Distribution Facility that serves a major transportation facility (may include International Airport, Mega Seaport, other air traffic control center, and international border crossing)
6 Distribution Facility that serves as a Level 1 Trauma Center as designated by the Office of Statewide Health Planning and Development
7 Distribution Facility that serves over 60,000 meters
B. IDENTIFICATION ANALYSIS
In performing this identification analysis, APU is assessing all distribution level facilities that are subject to its exclusive control, or if the facility is jointly owned, the joint ownership agreement identifies APU as the entity responsible for operation and maintenance. The specific types of distribution level facilities include distribution substations. Based on this scope, APU identified thirteen facilities that are subject to this identification analysis.
In addition, although not being classified as a distribution substation, 220/69 kV Substation “M” was also included in the analysis. Of the 14 facilities analyzed, only 69/12 kV Substation “A” fell within one of the categories listed above (regional public safety) and constitutes a Covered Distribution Facility.
11 The following table summarizes the results of APU’s identification analysis.
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 “A” N N N Y N N N
Substation “B” N N N N N N N
Substation “C” N N N N N N N
Substation “D” N N N N N N N
Substation “E” N N N N N N N
Substation “F” N N N N N N N
Substation “G” N N N N N N N
Substation “H” N N N N N N N
Substation “I” N N N N N N N
Substation “J” N N N N N N N
Substation “K” N N N N N N N
Substation “L” N N N N N N N
Substation “M” N N N N N N N
Substation “N” N N N N N N N
1) Cranking Path, Black Start
APU does not have any black start 6or cranking path that is necessary for the restoration of regional electric service and is not designated as a black start entity for maintaining regional reliability of the bulk power system under the California Independent System Operator (CAISO) operational control.
2) Military Installations
There are no military installations that are essential for national security and/or emergency response services in APU’s service territory. The nearest military installations that meet this criterion are the Los Alamitos Joint Forces Training Base located in the City of Los Alamitos and the Naval Weapons Station in the City of Seal Beach.
3) Regional Drinking Water/Wastewater Services
There are no regional drinking water or wastewater services located in the City of Anaheim.
6 Black start means a generating unit that has the capability to start without an outside electrical supply during blackouts.
Cranking path is a predetermined path where transmission lines can be utilized to start other generating power plants.
12 The primary source of regional drinking water supplies for the Los Angeles metropolitan area including Orange County is from The Metropolitan Water District of Southern California (MWD). MWD operates two major water treatment plants, located in the City of Yorba Linda and in the City of La Verne, that treat water before delivery to residents in Orange and Los Angeles counties. The regional wastewater treatment plants that serve municipalities in Orange County are managed and operated by the Orange County Sanitation District (OCSD). They are in the cities of Fountain Valley and Huntington Beach. These regional drinking water and wastewater treatment plants are located outside of APU’s service territory. 4) Regional Public Safety
There is one regional public safety establishment in the City of Anaheim. The Metro Cities Fire Authority, also known as Metro Net Fire Dispatch, is a 911 dispatch communications center for several Orange County cities. It is located in Anaheim and served by APU.
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. APU understands that a major police or fire department is defined as serving a population of 1.5 million with at least 1,000 sworn officers. Anaheim’s population is approximately 350,000 which is less than 1.5 million and the City of Anaheim Police and Fire & Rescue Departments have approximately 430 sworn police personnel and 210 sworn fire personnel, respectively. The Orange County Regional Emergency
Management and Loma Ridge
Emergency Operations are in the City of Irvine. The Orange County Sheriff’s Department and Orange County Central Jail are both located outside the City of Anaheim.
5) Major Transportation
There are no major transportation facilities in the City of Anaheim. A major transportation facility may include international airport, mega seaport, other air traffic control center, and international border crossing. APU understands major transportation facility to mean any transportation facility that has (1) an average of 600 or more flights per day or (2) over 50,000 passengers arriving or departing per day. The Anaheim Regional Transportation Intermodal Center (ARTIC) was reviewed and does not meet the threshold requirements.
13 6) Level 1 Trauma Center
There are no designated Level 1 Trauma Centers in Anaheim. A Level 1 Trauma Center is a medical emergency center as designated by the Office of Statewide Health Planning and Development. The nearest Level 1 Trauma Center is the University of California, Irvine (UCI) trauma center located in the City of Orange.
7) Over 60,000 Meters
APU has no distribution substations serving more than 60,000 customer meters.
Depending on geographic areas, APU’s distribution substations serve, on average, less than 10,000 meters per distribution substation.
IV. RISK ASSESSMENT (STEP 1B)
A. METHODOLOGY
Pursuant to the process identified in the Joint Proposal and D.19-01-018, APU 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.
To perform this risk analysis, APU evaluates 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 resilience and other measures in place.
B. MITIGATION MEASURES
D.19-01-018 identifies the specific mitigation measures that a utility should consider when performing a risk analysis. The following table lists these mitigation measures and provides APU’s additional clarification that is necessary to apply these measures to APU’s service territory.
14 Measure D.19-01-018 Description
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).
2 The availability of spare assets to restore a particular load. 3 The existing physical security protections to reasonably address the risk.
4 The potential for emergency responders to identify and respond to an attack in a timely manner.
5 Location and physical surroundings, including proximity to gas pipelines and geographical challenges, and impacts of weather. 6 History of criminal activity at the Distribution Facility and in the area. 7 The availability of other sources of energy to serve the load (e.g., customer owned back-up generation or storage solutions). 8 The availability of alternative ways to meet the health, safety, or security.
9 Requirements served by the load (e.g., backup command center or water storage facility).
C. RISK ASSESSMENT
Based on the process described in the Joint Proposal and the direction provided in D.19-01-018, APU has determined that it has one (1) Covered Distribution Facility that falls within one of the categories listed above as a result of the identification analysis in Section III-B.
APU has reviewed its existing programs and measures for the 69/12 kV Substation “A,” the Covered Distribution Facility, to determine how effective its existing programs and measures are to mitigate the risks of a physical attack.
APU takes physical security measures seriously and implements measures that meet or exceed physical security standards for its distribution facilities. Below are brief descriptions of APU’s security measures:
1) Existing Resiliency
APU distribution facilities, including the 69/12 kV Substation “A,” are designed with redundancies to provide system reliability. 69/12 kV Substation “A” has multiple tie lines with adjacent substations that can quickly pick up APU’s loads if they are dropped due to forced outages.
15 The Metro Net Fire Dispatch Center receives its primary service from a12kV circuit fed from the 69/12 kV Substation “A,” with alternative sources available from adjacent facilities to ensure continuity of service. In the event of a successful physical attack that causes damage to a transformer bank (worst-case scenario), the Metro Net Fire Dispatch Center could be quickly transferred to an adjacent transformer bank operating in parallel with the damaged bank. The Metro Net Fire Dispatch Center also has redundant 12kV power source that in the event of a circuit outage, it will be automatically transferred to another 12kV circuit in seconds via an Automatic Transfer Switch. In addition, there is a back-up generator at the Metro Net Fire Dispatch Center site that is readily available for emergency use in the event of a prolonged power outage that affects both the primary and emergency 12kV circuits.
2) Spare Assets
APU maintains an inventory of available spare assets (e.g. circuit breakers, disconnects, relays, capacitors, etc.) for its distribution facilities at a centrally located warehouse, for quick dispatch and replacement. In addition, APU maintains a 69/12kV mobile substation that can be deployed to any distribution facility to temporarily service load in the event of a transformer is damaged in a physical attack. It is discussed in more detail in Section VIII.A – Asset Management Program.
3) Existing Physical Security
All distribution substations have either tall block walls or chain-link fences and security gates that block public access. Some of APU’s newer distribution substations are enclosed inside a façade structure that blends in with the surrounding areas that significantly minimize risks of being a target of physical attack.
The 69/12 kV Substation “A” is a modern, fully enclosed facility rebuilt approximately fifteen years ago to enhance physical security. It is secured by controlled access, brick walls with locked gates, and a perimeter intrusion system. The building is equipped with security cameras, lighting, motion detection, and alarm systems, all integrated into SCADA for continuous 24/7 monitoring securing the substation equipment. In addition, an iron fence surrounds the structure to provide another layer of protection.
16 4) Emergency Responders
Departments can respond quickly, on average in less than 15 minutes, upon being notified of a substation security breach. APU routinely coordinates with police and fire personnel on local emergencies, and Anaheim dispatch is proficient with a direct line of communication to local responders, expediting response. For example, APU coordinates with Anaheim Fire & Rescue for review of APU’s Wildfire Mitigation Plan, and with Anaheim Police Department for investigations of customer fraud such as illegal use of electricity.
All APU distribution substations are generally located within five miles from an Anaheim police station, and within a few miles from an Anaheim fire station. APU field personnel are also located near APU distribution substations and can respond quickly in the event of an operational emergency. Furthermore, APU has system operators and troubleshooting field staff on duty 24 hours a day, 7 days a week.
5) Location
69/12kV Substation “A” is in an urban/suburban setting and surrounded by residential neighborhoods and commercial/industrial complexes. It is located on flat terrain and exposed to Mediterranean weather mostly throughout the year, hence there are no geographical or weather-related challenges. There are transmission and high-pressure distribution gas pipelines in Anaheim; however, none are found to be near the 69/12kV Substation “A”.
6) Criminal History
There have been few incidents involving APU’s distribution substations in the past. Generally, those incidents involved either theft of copper or minor vandalisms. 69/12 kV Substation “A” had one minor vandalism incident involving a broken glass window shortly following the substation upgrade more than 15 years ago. There were no further incidents reported since 2021. Criminal activity within a quarter-mile of Substation “A” over the past
six months have been mostly vandalism, auto theft, or larceny. 7) Back-up Generation
Most major customer loads, including City of Anaheim facilities, served by APU have back-up generation and/or preferred/emergency services. The
17 City facility hosting the Metro Net Fire Dispatch Center has both preferred/emergency services and an on-site emergency back-up generator.
8) Available Alternatives
Not applicable.
9) Customer Requirements
The Metro Net Fire Dispatch Center requires reliable service due to its critical function of dispatching emergency services to the area residents.
As discussed above, redundant and alternative sources have been installed to ensure continued electric service in the event of power interruption due to a physical attack.
The following table provides a summary of APU’s assessment of each mitigation measure for the 69/12 kV Substation “A”.
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
Substation
“A”
Yes Yes Yes Yes Urban /
Suburban
Minor
Vandalism
Yes N/A
As discussed above, 69/12 kV Substation “A” as well as other APU distribution facilities have multiple mitigating measures currently in place to effectively mitigate against potential risks of a physical attack.
V. COVERED DISTRIBUTION FACILITY MITIGATION PLANS (STEP 1C) APU has determined that it has one Covered Distribution Facility as a result of the identification analysis in Section III-B above. Furthermore, APU performed risk assessment of the Covered Distribution Facility and determined that the existing measures are more than adequate to effectively mitigate against risks of potential physical attacks. Therefore, additional mitigation measures are not required.
18 VI. 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, as 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 the entity or organization meets at least one of the following:
(1) at least one staff member holds either an ASIS International Certified Protection Professional (CPP) or Physical Security Professional (PSP) certification; (2) the entity or organization has demonstrated law enforcement, government, or military physical security expertise; or (3) the entity or organization is approved to do physical security assessments by the CPUC, Electric Reliability Organization, or similar electrical industry regulatory body.
B. IDENTIFICATION OF THIRD -PARTY REVIEWER
APU has selected NV5 as its Third-Party Reviewer. NV5 is a leading global provider of professional and technical engineering and consulting solutions with a strong management team and with a hundred years of combined industry experience.
The NV5 consulting team, whose member is ASIS International certified, conducted an independent review of APU’s Physical Security Plan.
C. PUBLIC RESULTS OF THIRD -PARTY EVALUATION
NV5 determined APU’s Physical Security Plan generally meets the Decision’s requirements. NV5’s recommended refinements to APU’s Physical Security Plan’s third‐p
arty evaluation process to strengthen compliance with CPUC Decision 19 ‐01‐018
are outlined below.
19 Recommendation 1: Substation “M” is not classified by APU as a distribution substation; it is recommended that the Physical Security Plan explicitly acknowledge any physical security risk assessment applicable to Substation “M”. If a physical security risk assessment for Substation “M” is required under any such regulatory framework and is currently in progress, recommend the plan state that the assessment is being completed and identify the applicable regulatory authority.
Recommendation 2: Recommend that the writer indicate changes that have taken place in the 5-year period between the 2021 assessment and the 2026 assessment.
Recommendation 3: The assessment lists nine “security measures” with brief statements. Recommend that more details and updates be included in the report.
The following are some specific examples:
1. Under “Existing Resiliency”, the report mentions existing tie-lines to other substations. Recommend identifying those connections/substations in the assessment.
2. Under “Existing Physical Security” the report states that there is access control (ACS), intrusion detection (IDS), and video surveillance (CCTV) available at Substation “A. Recommend The following items should be included:
a. A simple layout of the substation in plan form with devices shown (locations of cameras, motion detectors, and door control). This floor plan should be detailed enough to show rooms and doors and corresponding physical security devices so that proper coverage can be confirmed.
b. A list of devices (specifically cameras) with model numbers and dates as to when they were last updated. This is particularly important as cameras typically have about a 5-year life cycle.
3. Under “Emergency Responders”, the report states that response times are approximately 15 minutes away in an emergency, but no mention as to where the response would normally come from. This information would be helpful in evaluating that response.
4. Under “Criminal History” Some information has been provided as to the safety of the area around the building, however no references have been provided to validate that information. Recommend utilizing a statistical tool (CrimeCast Report or similar) to better document the threat level.
20 D. APU IMPLEMENTATION OF THIRD -PARTY RECOMMENDATION Below are APU’s decision and reasons for either accepting or declining NV5’s three recommendations:
Recommendation 1: Substation “M”, classified as non-distribution substation, is not under any physical security assessment as required by any regulatory authority. However, APU included Substation “M” along with other distribution substations in its Physical Security Plan for completeness.
Recommendation 2: As recommended, the changes that have taken place in the 5-year period between the 2021 assessment and the 2026 assessment are summarized in the Executive Summary.
Recommendation 3: The additional details as recommended may pose added physical security risks, thereby the security of the Covered Distribution Substation is potentially compromised.
1. As critical infrastructures, existing tie-lines to other substations utilized as emergency feeders are not explicitly identified for security reasons.
2. Similarly to critical infrastructure, the layout or locations as well as the models of the security, control and surveillance electronic devices for Substation “A” are not disclosed for security reasons.
3. The specific locations where the emergency responses come from would provide approximate indications of the Covered Distribution Substation, therefore are not included in the plan.
4. APU keeps track of and records all incidents at all the distribution substations. This information is shared with the Anaheim Police Department, and can be readily validated.
VII. VALIDATION (STEP 3)
A. SELECTION OF QUALIFIED AUTHORITY
APU has selected the Anaheim Police Department (APD) who has sufficient familiarity with relevant federal, state, and local standards relating to law enforcement and public safety in order to serve as the “qualified authority” for the review of APU's 2026 Physical Security Plan.
21 B. RESULTS OF QUALIFIED AUTHORITY REVIEW
Based on its review, APD deems APU’s 2026 Physical Security Plan adequate.
VIII. NARRATIVE DESCRIPTIONS FOR APU PHYSICAL SECURITY PLAN APU has determined that it has one Covered Distribution Facility as a result of the identification analysis in Section III-B above.
The following are discussions of APU’s current programs that support distribution substation physical security.
A. ASSET MANAGEMENT PROGRAM
APU maintains an inventory of spare essential substation equipment for timely restoration of power following emergency conditions, either manmade or natural disasters. Critical substation equipment such circuit breakers, disconnects, etc. are stored locally at APU’s centrally located warehouse, for quick dispatch of spare equipment. Due to the critical function and necessity of transformers, APU has a mobile transformer that can be relocated, connected, and energized relatively quickly.
APU’s asset management program has mechanisms and processes to monitor and track assets. The program details the asset’s identification number, equipment type, age, location, manufacturer, maintenance activities, and condition. Historic equipment failure rate and asset criticality are important considerations in determining the level and type of spare equipment needed.
New equipment is ordered timely, as spare equipment is utilized, to ensure the minimum level of essential spares are available in an emergency.
B. WORKFORCE TRAINING AND RETENTION PROGRAM
APU has proactively developed and maintained a highly qualified workforce that consists of line mechanics, substation test technicians, substation electricians, electrical inspectors, system operators, and troubleshooters. These well-qualified, highly skilled staff can respond quickly to emergency situations that result in power interruptions to repair, replace, and promptly restore electric service. APU has an on-the-job training program for apprentices that provides hands-on experience and prepares them to become journey-level qualified
22 technicians. Regular training and guidance are supervised by a senior journey level employee.
APU provides training for its field staff to maintain and enhance their knowledge and skill sets, not only for routine maintenance and operation activities, but also performance in emergency situations. APU encourages employee participation in specialized education and certification programs and provides incentive pay to support the development and retention of a qualified workforce.
Additionally, training is conducted annually to prepare for multiple types of natural disasters or incidents, including physical security risks that could result in widespread power interruptions and that require activation of Anaheim’s Emergency Operations Center (EOC) and APU’s Electric Department Operations Center (DOC). Specific emergency training scenarios are conducted annually, either as part of the larger department-wide training or through table-top exercises with key personnel responsible for electric operations.
APU values and recognizes essential services provided by staff. APU’s compensation structure is designed to remain competitive with the market and include salary and benefit packages that align with employees’ experience and skill sets. In addition to the competitive compensation structures, APU provides additional incentive pay and non-monetary benefits that help retain highly qualified staff. APU holds annual all-hands meetings to celebrate APU’s accomplishments and to recognize employee contribution. Throughout the year, APU also organizes employee appreciation events, such as department-wide picnic, and an Employee Appreciation Day for its staff.
C. PREVENTATIVE MAINTENANCE PLAN
APU’s maintenance program focuses on keeping substation and associated physical security equipment fully functional and capable of supporting the safe reliable operations of facilities that serve critical infrastructure.
APU substations are designed, constructed, operated, and maintained to preserve critical assets in a condition that supports effective physical security protection and reduces vulnerability to unauthorized access, damage, or other security threats.
Additionally, APU conducts routine substation inspections to assess equipment conditions and to verify the integrity of physical security systems.
23 Qualified substation personnel inspect each of the 14 substations monthly. These inspections evaluate for anomalies and security vulnerabilities, including signs of damage, tampering, or trespassing. Integrity of perimeter security components, such as fencing and gates, is visually verified during each inspection. Results found are prioritized based on the potential impact to safety and/or reliability.
APU substations are equipped with layered security measures to deter, prevent, and detect illegal entries or breach of substation physical security. These security measures include:
• Block walls or fences, with an ongoing Capital Improvement Program to replace fences with block walls
• Security gates
• Security cameras
• Entry ID verification and logging
• Intrusion detection system
• Lighting
The electronic security measures are linked to APU’s SCADA system via fiber-optic communications system for continuous alarm and monitoring. Electronic security measures are comprehensively inspected every two years, and overhauled when needed. Any security system outage is addressed promptly, and temporary measures, such as mobile camera units, are implemented, until the system is fully restored or secured.