Attachment A
PASADENA WATERAND POWERPHYSICAL SECURITYPLAN - 2026UPDATE
PUBLIC REPORT ON PWP'S PHYSICAL SECURITY PLANFOR DISTRIBUTION-LEVEL FACILITIES
TABLE OF CONTENTS
1. Overview.......................................................................................
A. Executive Summary....B. Goal of Physical Security Plan ..............................................
C. Description of PWP ..........................
D. Results of Physical Security Plan Assessment......................
II. Background............................................................................
III. Plan Development Process...................................................
A. Physical Security Principles.................................................
B. Physical Security Plan Development Process......
STEP 1: Assessment/Plan Development................STEP 2: Independent Review......................................................
STEP 3: Validation.........................................................................STEP 4: Adoption..........................................................................
STEP 5: Maintenance...................................................................STEP 6: Repeat Process................................................................
IV. Identification of Covered Distribution Faciliites (Step 1A) A. Identification Factors.............................................................
B. Identification Analysis............................................................
V. Risk Assessment (Step 1 B) ..............................
A. Methodology..........................................................................
B. Mitigation Measures..............................................................
C. Risk Assessment......................................................................
D. Process....................................................................................
1. Security Index..................................................................... ....2
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.4
.4.4
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2. Resiliency Index......
3. Risk Index...........................................................................................
VI. Distribution Facilities Upgrade/Replacement Plans (Step 1C)........VII. Independent Evaluation and Response (Step 2) .............................
A. Requirements for a Qualified Third-Party Review..............................B. Identification of Third-Party Reviewer.................................................
C. Public Results of Third-Party Evaluation..............................................
D. PWP Response.......................................................................................
VIII. Validation (Step 3)................................................................................
A. Selection of a Qualified Authority.......................................................B. Results of the Qualified Authority Review.......
C. PWP Response to The Qualified Authority Review..........
IX. Narrative Descriptions for Physical Security Plan ..............................
A. Asset Management Program..............................................................
B. Workforce Training and Retention Program......................................
C. Preventative Maintenance Plan....................................................... 14 ...................18
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I. OVERVIEW
A. EXECUTIVE SUMMARY
As consistent with the Joint IOU/POU Straw Proposal and D.19-01-018, The City of Pasadena, Water and Power (PWP) have reviewed and updated our Physical Security Plan that was firstsubmitted in June 2021.
PWP repeated the six-step development process and thoroughly performed the identificationand risk assessments.
As a result of the assessment, PWP has determined that there were no changes in the Covered Distribution Facility list when compared to 2021. The same facilities identified before remain unchanged, with the facilities being: Substation J, Substation F, and Substation K.
During the past five years, PWP has actively and continually implemented several physical security improvements to our various distribution substations and other related facilities. Theseimprovements include the addition of security cameras, lighting, razor wire, and additional chains to gates. These security improvements are part of PWP's ongoing effort in securing itselectrical infrastructure from any potential physical security risks. Below is a summary of specific improvements during the past five years, and expected security enhancements in the nearfuture:
a.
b.
Updates from PWP's 2021 Physical Security Plan
Add barbed wire to multiple stationsReinforce chain-link fences and gatesImprovement of communication at multiple stations
1. Improve security camera coverage
2. Improve alerts for suspicious activity
Planned security enhancements
Seal unnecessary gatesEstablish a regular camera cleaning schedule 00 0
0 0
B. GOAL OF PHYSICAL SECURITY PLAN
Ensuring the safety of its facilities is a top priority for PWP, and PWP prioritizes safety in all aspects of its design, operation, and maintenance practices. The overarching goal of this PhysicalSecurity Plan is to describe PWP's risk management approach toward distribution system physical security, with appropriate consideration of resiliency, impact, and cost.
PWP recognizes the importance of securing the safety and reliability of its electric system and, therefore, PWP offers the following in response to CPUC Decision 19-01-018.PWP Physical Security Plan - 2026 Update 1 C. DESCRIPTION OF PWP
Pasadena is an ethnically diverse community that is home to nearly 140 thousand peoplemaking it the 183rd-largest city in the United States. As the ninth largest city in Los AngelesCounty, Pasadena is one of the primary cultural centers in the San Gabriel Valley. The Citycovers approximately 23 square miles. There are over 100,000 jobs in a wide variety of industriesin the City of Pasadena. Pasadena is the home to the Rose Bowl and annual Rose Parade.
D. RESULTS OF PHYSICAL SECURITY PLAN ASSESSMENT
After evaluating all distribution-level facilities in PWP's service territory, PWP decided to assess all twelve (12) distribution and receiving stations under its control. Out of these facilities, only three were identified and evaluated as Covered Distribution Facilities per the Joint IOU/POU Straw Proposal screening factors and are subject to the need for a risk assessment.
1. Substation J
2. Substation K3. Substation F
For these three covered distribution facilities, PWP performed an evaluation of the risk of a potential physical attack and whether existing security and resiliency measures appropriately mitigate identified risk.
After determining the three candidate facilities for risk assessment, PWP utilized the same scoring method developed in the PWP's 2021 Physical Security Plan to determine the Risk Index for eachof the covered facilities. The Security Index and Resiliency Index were developed by assigning ascore between 0-10 in multiple categories as shown in the Risk Assessment section. After the total security and resiliency computation was processed, the Risk Index for each individual facility was calculated as follows:
Risk Indexpaciuty i = Security Indexpaciiity i * Resiliency Indexpacuity i PWP determined that the three Covered Distribution Facilities have sufficient existing security and resiliency measures in place to effectively mitigate the identified risks of a successfulphysical attack.
An independent evaluation was conducted by Radian Generation as the third-party reviewer,and subsequently reviewed and validated by the Pasadena Police Department, which serves as a qualified authority. The conclusion of the Radian Generation and Pasadena Police Department review was that PWP's Physical Security Plan - 2026 Update is deemed to be adequate.
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 17PWP Physical Security Plan - 2026 Update 2 transformers. These individuals also cut nearby fiber-optic telecommunication cables owned by AT&T and Level Three Communications. In response to the attack, the Federal EnergyRegulatory Commission (FERC) directed the North American Electric Reliability Corporation (NERC) to develop new physical security requirements, resulting in the creation of CIP-014.
At the state level. Senator Jerry Hill authored SB 699 (2014), directing the CPUC to "consider adopting rules to address the physical security risks to the distribution systems of electrical corporations." In response to SB 699, the CPUC's Safety and Enforcement Division, RiskAssessment and Safety Advisory Section (RASA) prepared a white paper proposing a new requirement for investor-owned utilities (lOUs) and publicly owned utilities (POUs) to develop security plans that would identify security risks to their distribution and transmission systems and propose methods to mitigate those risks. The CPUC hosted a series of workshops to better understand the state of utility physical security protections and to seek input on refining theirproposal.
In order to support a statewide improvement of how utilities address distribution level physical security risks, the California Municipal Utilities Association (CMUA), which is the statewide tradeassociation for POUs, coordinated with the state's lOUs to develop a comprehensive Straw Proposal' (Joint IOU/POU Straw Proposal) for a process to identify at-risk facilities and, ifnecessary, develop physical security mitigation plans. As a member of CMUA, PWP staffparticipated in the development of the Joint IOU/POU Straw Proposal through a CMUA workinggroup as well as through direct meetings with the IQUs. 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 distributionfacilities where the identified risks are not effectively mitigated through existing resilience/securitymeasures, developing a mitigation plan; (4) obtaining a third party review 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, RASA recommended that the utility mitigation plans include: (1) an assessment of supply chain vulnerabilities; (2) training programs for law enforcement andutility staff to improve communication during physical security events; and (3) an assessment ofany nearby communication utility infrastructure that supports priority distribution substations.In early 2019, the CPUC approved Decision (D.) 19-01-018, which adopted the Joint IOU/POUStraw Proposal as modified by the RASA proposal, with additional clarifications and guidance.
D.19-01-018 clarified that where there is a conflict between the Straw Proposal and the RASA proposal, then it is the rule in the RASA proposal that shall apply.2' Straw Proposal available at:
httDS://docs.CDuc.ca.aov/PublishedDocs/Published/GOOO/M260/K335/260335905.PDF. 2 D.19-01-018at43, footnote 58 ("Should there be any question of which shall predominate should there be any incongruity or conflict between a utility or SED RASA recommended rule, the SED RASA rule shall apply.").
PWP Physical Security Plan - 2026 Update
3 D.19-01-018 asserted that the POUs should utilize the Physical Security Plan process described therein. PWP issued the 2021 Physical Security Plan which was adopted by City Council on June 14, 2021.3 This report serves as an update to PWP's 2021 Physical Security Plan to reflect on PWP's existing commitment to safety and to protecting its ratepayers' investment by taking reasonable and cost-effective measures in an effort to safeguard key assets of its distribution system.
PLAN DEVELOPMENT PROCESS
A. PHYSICAL SECURITY PRINCIPLES
PWP has taken a risk-based approach toward distribution system physical security, withappropriate considerations of resiliency, impact, and cost. This approach, consistent with theJoint IOU/POU Straw Proposal, identified several principles to guide the development of PWP'ssecurity plan. 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 systemsand unique situations, consistent with a risk management approach.4. Protecting the distribution system should consider both physical security protection andoperational resiliency or redundancy.5. The focus should not be on all Distribution Facilities, but only those that risk dictateswould require additional measures.6. Planning and coordination with the appropriate federal and state regulatory and lawenforcement authorities will help prepare for attacks on the electrical distribution systemand thereby help reduce or mitigate the potential consequences of such attacks.
B. PHYSICAL SECURITY PLAN DEVELOPMENT PROCESS
PWP utilizes a multi-step process to develop a Security Plan that is consistent with the JointIOU/POU Straw Proposal and D.19-01-018. The relevant six steps of that process are the following:
STEP 1: ASSESSMENT/PLAN DEVELOPMENT
3 Adoption of 2021 PWP Utility Security Plan at:
httDS;//ww2.cityofDasadena.net/2021 %20Aaendas/Jun 14 21 /AR%208.pdfPWP Physical Security Plan - 2026 Update 4 PWP prepares a Draft Physical Security Plan through the process set forth in Steps 1A, 1B,and 1C.
ISTEP 1A: IDENTIFY COVERED DISTRIBUTION FACILITIES
PWP evaluates all distribution-level facilities in its service territory that are subject to its control to determine if any of these facilities meet D. 19-01-018's definition of a Covered Distribution Facility using the seven factors identified in the Joint IOU/POU Straw Proposal.
I STEP 1B: PERFORM RISK ASSESSMENT
For ever/ individual Covered Distribution Facility identified pursuant to Step 1A, PWPperforms an evaluation of the potential risks associated with a successful physical attack on that facility, and whether existing grid resiliency, back-up generation, and/or physicalsecurity measures appropriately mitigate identified risks. [•^ISTEP 1C: DEVELOP MITIGATION PLAN
If there are any individual Covered Distribution Facilities where the Risk Assessmentperformed pursuant to Step 1 B finds that the existing mitigation and/or resiliencymeasures do not effectively mitigate the identified risks, then PWP will develop aMitigation Plan for that Covered Distribution Facility. The Mitigation Plan will use a riskbased 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).
PWP Physical Security Plan - 2026 Update
5 I STEP 2: INDEPENDENT REVIEW
For every Physical Security Plan cycle, PWP will document the results of the identification process,risk assessment, and Mitigation Plan development performed pursuant to Steps 1A,1B, and 1C.
This documentation in combination with narrative description in Section IX, constitutes PWP's Draft Physical Security Plan. The Draft Physical Security Plan is submitted to a Qualified Third Party for Independent Review. The Qualified Third-Party Reviewer will then issue an evaluation that identifies any potential deficiencies in the Draft Physical Security Plan as well as recommendations for improvements. PWP will then modify its plan to address any identified deficiencies or recommendations or will document the reasons why any recommendations were not adopted. The combination of the Draft Physical Security Plan, the non-confidential conclusions of the Qualified Third Party Reviewer, and PWP's responses to the Qualified Third Party Review will constitute PWP's Physical Security Plan.
STEP 3: VALIDATION
PWP will submit its Physical Security Plan to a qualified authority for review. Such entity willprovide additional feedback and evaluation of PWP's Physical Security Plan and, to the extentthat this entity is authorized, deem the Physical Security Plan as adequate.
STEP 4: ADOPTION
PWP's Physical Security Plan will be presented to and adopted by Pasadena City Council at a public meeting.
STEP 5: MAINTENANCE
PWP will refine and update the Utility Security as appropriate and as necessary to preserve planintegrity.
STEP 6: REPEAT PROCESSPWP will repeat this six-step process at least once every five years.
IV. IDENTIFICATION OF COVERED DISTRIBUTION FACILIITES (STEP 1 A) As described in Section III, Step 1A of the Physical Security Plan process involves assessing all distribution-level facilities that are subject to the control of PWP to determine which facilities areCovered Distribution Facilities subject to the need for a risk assessment. This Section describes the factors that PWP used to evaluate its distribution facilities and the results of its evaluation.
PWP Physical Security Plan - 2026 Update
6 A. IDENTIFICATION FACTORS
The Joint IOU/POU Straw Proposal defines seven screening factors to determine if a facility is a Covered Distribution Facility. Some factors require additional definitions and/or clarifications inorder to be applied to PWP's facilities. The following Table provides the Joint IOU/POU Straw Proposal's Factors as modified/clarified by PWP.
Table IV-1: Identification Factors
Factor Joint IOU/POU Straw Proposal Description Additional Clarification Distribution Facility necessary for crank path,black start or capability essential to therestoration of regional electricity service that arenot subject to the California Independent SystemOperator's (CAISO) operational control and/orsubject to North American Electric ReliabilityCorporation (NERC) Reliability Standard CIP-014-2 or its successors Substation F was considered critical for acrank path and black start of PWPgenerators feeding the region. 2 Distribution Facility that is the primary source ofelectrical service to a military installationessential to national security and/or emergencyresponse services (may include certain airfields,command centers, weapons stations,emergency supply depots) City of Pasadena does not house anymilitary facility whether it is for the state ornational army. 3 Distribution Facility that serves installationsnecessary for the provision of regional drinkingwater supplies and wastewater services (mayinclude certain aqueducts, well fields,groundwater pumps, and treatment plants) An installation provides "regional drinkingwater supplies and wastewater services" if itis the primary source of drinking watersupply or wastewater services for over 15,000 customer accounts for an area with
a population of over 100,000.Substation J was considered critical forwater facilities in case of prolongedoutages. 4 Distribution Facility that sen/es a regional publicsafety establishment (may include CountyEmergency Operations Centers; county sheriff'sdepartment and major city police departmentheadquarters; major state and county fireservice headquarters; county jails and state andfederal prisons; and 911 dispatch centers) PWP defines "regional public safetyestablishment" as any of the following: (1)Headquarters of a major police or firedepartment serving 1.5 million populationwith at least 1,000 sworn officers; (2) CountySheriff's Department Headquarters; (3)County Emergency Operations Center; (4)County/State Fire headquarters; (5) aCalifornia State Prison; (6) a United StatesPenitentiary; or (7) a Federal CorrectionalInstitute.City of Pasadena has its own Police andFire departments. The Police departmenthas 230 sworn officers stationed at fourlocations, including the 911 DispatchCenter. The Fire department has EightStations serving the City of Pasadena andadjacent neighborhoods. No Federal, State PWP Physical Security Plan - 2026 Update
7 or County law enforcement offices are
within the borders of Pasadena.Substation K was considered critical foremergency services. 5 Distribution Facility that serves a majortransportation facility (may include InternationalAirport, Mega Seaport, other air traffic controlcenter, and international border crossing) In addition to the facilities listed in the JointIOU/POU Straw Proposal, PWP defines a"major transportation facility" as anytransportation facility that has (1) anaverage of 600 or more flights per day; or(2) over 50,000 passengers arriving ordeparting per day.None of the above facilities exist within theborders of Pasadena. However, PWP servessix LA Metro A Line train stations (none ofthem is a hub or a major station). The A Linetransports less than 20,000 passengers a daythroughout 22 stations (from Chinatown toPomona including Pasadena). 6 Distribution Facility that serves as a Level 1Trauma Center as designated by the Office ofStatewide Health Planning and Development.
City of Pasadena serves only one Level 2Trauma Center within its boundaries. Noother Trauma Center is within the servicearea of Pasadena Water and Power.No single distribution facility was identifiedas critical for the operation of the Level 2Trauma Center since multiple distributionfacilities are providing service/back up tothe facility. 7 Distribution Facility that serves over 60,000 meters None of PWP's Distribution facilities directly serve more than 60,000 customers each.PWP serves approximately 68,000 meters.However, Substation J was consideredcritical because the main function of thisfacility is to distribute power to the otherfacilities. No customers are being serveddirectly from this facility.
B. IDENTIFICATION ANALYSIS
In performing this identification analysis, PWP assessed all distribution level facilities under its exclusive control. PWP is the only entity responsible for operation and maintenance for thesetwelve (12) distribution and receiving facilities. Of these 12 facilities, three facilities fall within atleast one of the categories listed above. These three facilities were evaluated as Covered Distribution Facilities per the Joint IOU/POU Straw Proposal screening factors and are subject to the need for a risk assessment.Table IV-2 summarizes the results of PWP's identification analysis. If the final score of any facility is greater than or equal to one (1), then PWP considers this facility as Covered Distribution Facility.PWP conducted a Risk Assessment analysis for these facilities as described in Section V.PWP Physical Security Plan - 2026 Update 8 jl
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V. RISK ASSESSMENT (STEP 1 B)
A. METHODOLOGY
Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, PWP willassess the potential risks associated with a successful physical attack on each of the CoveredDistribution 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, PWP evaluates the relative risk that (1)a physical attack on aCovered Distribution Facility will be successful considering the protective measures in place; or (2) that the impacts of a successful attack will be mitigated due to resiliency and other measures in place.
B. MITIGATION MEASURES
D.19-01-018 identifies the specific mitigation measures that a utility should consider whenperforming this risk analysis. The following table lists these mitigation measures and provides PWP's additional clarifications that are necessary to apply these measures to PWP's territory.
Table V-1: Mitigation Measures
Measure D.19-01-018 Description Additional Clarification 1 The existing system resiliency and/orredundancy solutions (e.g., switching theload to another substation or circuitcapable of serving the load, temporarycircuit ties, mobile generation and/orstorage solutions).
There are switching opportunities available on thesubstation level or distribution level. Most circuitshave ties, often to other distribution substations. 2 The availability of spare assets to restore a particular load. PWP maintains a spare parts inventory.3 The existing physical security protectionsto reasonably address the risk.
Pasadena Police Department (PPD) surveyedPWP distribution facilities in 2026 and providedcommendations and recommendations. PWP haslaunched an upgrade project to improve securityat each of the Covered Distribution Facilities perPPD recommendations. 4 The potential for emergency respondersto identify and respond to an attack in atimely manner.
Each facility is evaluated based on the likelihoodthat a law enforcement officer would generallybe able to arrive at the Covered DistributionFacility within 15 minutes of a report from thepublic of a break-in or attack, or of PWP notifyinglaw enforcement agency of a physical securityincident/attack at the facility.
PWP Physical Security Plan - 2026 Update
10 5
Location and physical surroundings,including proximity to gas pipelines andgeographical challenges, and impactsof weather.
PWP evaluated this element based on theproximity of the Covered Distribution Facility topopulated areas and the extent to which theinterior of the facility is shielded from view andaccess due to walls, vegetation, or other physicalobstructions. PWP removed or is in the process ofremoving vegetation that may facilitatebreaching into any of the distribution facility. 6 History of criminal activity at theDistribution Facility and in the area.
PWP evaluated the property crime rates in theimmediate vicinity of the Covered DistributionFacility and compared those crimes rates toproperty crime rates for the county and the stateto determine if the area is subject to a higher thanaverage incidence of property related crimes. 7 The availability of other sources ofenergy to serve the load (e.g., customerowned back-up generation or storagesolutions).
Many critical customers have backupgenerators.
The availability of alternative ways tomeet the health, safety, or security.
No additional clarification.
9 Requirements ser/ed by the load (e.g.back up command center or waterstorage facility).
No additional clarification.
C. RISK ASSESSMENT
Based on the process described in the Joint IOU/POU Straw Proposal and the direction provided in D.19-01-018, PWP has determined that of the three Covered Distribution Facilities identified in Section IV, the existing programs and measures effectively mitigate the risks of a physical attackfor those Covered Distribution Facilities.This section provides an outline for PWP's methodology to address existing risk in the distribution facilities. The framework will enable PWP to assign an individual score for each of its covered facilities, which can later be used to prioritize maintenance activities and capital expenditures interms of physical security of distribution facilities.
A Security evaluation along with a Resiliency assessment provides the basis for a Risk-based approach, where Resiliency is related to the ability of PWP system/facility to recover from an incident. Security is associated with the present deterrents to prevent any intruder(s)/attacker(s) from breaching the facility. Risk is measured as the combination of these two metrics.
The objective of developing this methodology is to properly identify and rate the security distribution facilities that may represent the greatest risk to the PWP power system. In order tocarry out this process and achieve valuable results, accurate and updated security data isrequired. Even though ever/ component of the electric system will always have an inherent riskof failure, it is essential for PWP to understand the assets risk level, becoming aware if any failureinstance is predictable and have reasonable spare parts to service assets in case of failure.
D. PROCESS
The key steps to develop the algorithm are summarized below:
PWP Physical Security Plan - 2026 Update
11 Collect, update, and prepare the security data for ever/ Covered Distribution Facility under analysis.Assign factors and modifiers for Security Index calculation.Compute the security index based on physical and operating conditions.Identify and quantify impact and consequences of loss/failure for each facility.Calculate Resiliency Index based on loss/failure effects and impacts.
Compute Risk Index for each Covered Distribution Facility.Identify the facilities in the highest risk category.Schedule upgrade, retrofit or maintenance work, projecting required funds on annualbasis, and preparing Capital Improvement Programs (CIPs).
This methodology can be applied to any distribution facility and the analysis is expected to produce useful results only if accurate and updated system data is utilized.1. SECURITY INDEX Physical Security is accomplished by performing an assessment of the covered facility and the surrounding premises. Security Index is a measure of precautions taken to deter intrudersand restrict their visibility or ability to breach into the facilities, including service interruption tocritical customers, and adverse impact on the safety of the public and PWP staff.The Security Index can be explained as a numerical representation of the facility importancefor normal system operation, and the impact to the system if that facility is lost due anattack, theft or vandalism. This metric remains constant until factors affecting it change.
Table V-1 provides details on different factors that impact the calculated security index foreach facility as modified/clarified by PWP. For simplicity, each security measure was given an equally-weighted score on 10-point scale based on conditions related to this measure as detailed in the following tables.
Security Index results are shown in Table V-2: Security Index for Covered Distribution Facilities.The Security Index for each covered facility is calculated by subtracting the average score from perfect 10 score.
PWP Physical Security Plan - 2026 Update
12 Measure: Fences/ Walls
Fence/Walls Condition ScoreChain Link Fence Alone 5 pointsChain Link Fence with Outriggers or Barbed Wire 8 points Masonry/Brick Wall Alone 8 pointsMasonry/Brick Wall with Outriggers or Barbed Wire 10 points Measure: Gates/ Controlled Entry
Gates Condition ScoreChain Link Gate Alone 5 pointsMetal Gate Alone 10 points Measure: VeaetgtiQn_Control / Perimeter Clearance
Vegetation/Perimeter Control Condition Score
No 0 pointsPartially 5 points
Yes 10 points
Measure: Electronic Surveillance
Surveillance Condition ScoreNo 0 pointsYes 10 points
Measure: lllumination/Motion Sensors
Illumination Condition Score
No 0 points
Yes 10 points
Measure: Parking Control/Barriers
Parta'ng Control/Barriers Condition ScoreNo 0 pointsPartially 5 pointsYes 10 points PWP Physical Security Plan - 2026 Update
13 Measure: Criminal History in Facility Surroundings
Criminal History Condition ScoreAbove Average 0 pointsAt Average 5 points Below Average 10 points
Measure: Existing Gas Lines /Location Vulnerability
Existing Gas Lines /Location Vulnerability
Condition
Existing Gas Lines / Location is VulnerableExisting Gas Lines / Location is not VulnerableNo Existing Gas Lines / Location is VulnerableNo Existing Gas Lines / Location is not Vulnerable Score
0 points5 points5 points
10 points
Measure: Required Time for a police car to reach any Substation Time required for a Police car to reach any
Substation ConditionMore than 15 minutesWithin 10 minutesWithin 5 minutes Measure: Presence of CriticaLCustomers
Presence of Critical Customers Condition
Two or more Critical CustomersOne Critical Customer
No Critical Customers
Score
0 points
5 points
10 points
Score
0 points
5 points
10 points
2. RESILIENCY INDEX
The Resiliency assessment of electrical facilities is associated with the ability of the distribution system to minimize the negative impacts of infrequently occurring adverse events such as aterrorist attack, theft or vandalism. Resiliency Index is a measure of preparations taken to restore operations of the electric system/circuit due to any incident at the Covered Distribution Facilities, including service interruption to critical customers that may impact onthe safety of the public or PWP staff.
PWP Physical Security Plan - 2026 Update
14 The Resiliency Index can be explained as the numerical representation of the facilities ability to recover if that facility is lost or damaged due to an attack, theft or vandalism. This metricremains constant until factors affecting it change. Table V-1 Table V-3 provides the factorsthat impact the calculated resiliency index for each facility as modified/clarified by PWP. Forsimplicity, each resiliency measure was given an equally-weighted score on 10-point scale based on conditions related to this measure as detailed in the following tables.Resiliency Index results are shown in Table V-3: Resiliency Index for Covered DistributionFacilities. The Resiliency Index for each covered facility is calculated by subtracting the average score from perfect 10 score.
Measure: Circuit Ties within Substation Services Areas
Ties with Adjacent Circuits from Same Substation Score
One Tie 5 points
Two Ties 8 pointsThree or more Ties 10 points
Measure: Circuit Ties within Adjacent Substation Services Areas Ties with Adjacent Circuits from DifferentSubstation
Score
One Tie 5 points
Two Ties 8 points
Three or more Ties 10 points
Measure: Availability of Mobile /Free Standing Transformer Availability of Mobile /Free Standing Transformer Score No 0 points
Yes 10 points
Measure: Availability of Back up Generation / Battery Storage to Serve Critical Customers Availability of Back up Generation / BatteryStorage to Serve Critical Customers Score
No 0 pointsYes 10 points
Measure: Availability of Contracts with Vendors for Engineering Services or Spare Parts Availability of Contracts with Vendors forEngineering Services and/or Spare Parts Score
No Contracts for Engineering Services nor SpareParts
0 points
Availability of Contracts for either EngineeringServices or Spare Parts 5 points
Availability of Contracts for both EngineeringServices or Spare Parts 10 points
PWP Physical Security Plan - 2026 Update
15 Measure: Availability of PWP Emergency Responders
Availability of PWP Emergency Responders Score
No 0 pointsYes 10 points
Measure: Availability of Mutual Aid Agreements on Local, State and National Levels Availability of Mutual Aid Agreements Score
Local Level 5 pointsLocal and State Levels 8 pointsLocal, State and National Levels 10 points Measure: Ability to Remotely Isolate/ Restore Services
Ability to Remotely Isolate/ Restore Services Score
None 0 pointsPartially 5 points
All equipment 10 points
Measure: Ability to Provide Services Under N-1 Conditions N-1 Reliability ScoreNo 0 pointsPartially - Excluding periods of extreme heatwaves 5 pointsAll Times including periods of extreme heatwaves 10 points Measure: Presence/Readiness of Backup Dispatch /Command Center Presence of Critical Customers Condition ScoreNo 0 pointsPartially 5 points All Times including periods of emergency state 10 points PWP Physical Security Plan - 2026 Update
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|3. RISK INDEX
After the Security Index and Resiliency Index computation process is finished, a Risk Index foreach individual facility is calculated, as follows:
Risk Indexpaciiity i = Security Indexpaciiity i * Resiliency Index Facility i Asset management systems usually represent risk calculation in a matrix, where the horizontaland vertical axis represent the Resiliency and Security scores between 1 and 10, respectively.The cells inside the matrix are the resulting risk index between 1 and 100, as shown Table V-4.
Table V-4: Distribution Facility Risk Index Matrix (Security x Resiliency) s
•u
sI
10 10
97654
3 2
1 10
98 7
65 432
1 20
181614
1210
864
2 302724
21 181512
9 6
3 403632
282420
1612
8 4
50454035302520
1510
5 60
54 4842363024
1812
6 70635649423528
21 14
7 72 ti
w
6456484032
24 16
8 72635445362718
9 70
60 5040
3020
10 1 234567
Resiliency Index
9 10
After performing the risk calculation, the covered distribution facilities under analysis are grouped in categories based on their risk scores, as depicted in Table V-5.
Table V-5: Risk Categories
Description
Very High Risk Facility
High Risk Facility
Medium Risk Facility
Low Risk Facility
Color
Brown
Yellow
Green
Risk Index Interval
76-100
50-75
26-50
1-25
Facilities inside the red category of the Risk Matrix -if any- will be addressed first. The Risk Index for our Covered Distribution Facilities are listed Table V-6.
PWP Physical Security Plan - 2026 Update
18 Table V-6: Risk Index for Covered Distribution Facilities Substation Name Resiliency Index "A" Security Index "B" Risk Index (A x B) Overall Physical Security ResultSubstation F 3.50 4.10 14.35 Low Risk Facility - PassedSubstation J 4.50 3.50 15.75 Low Risk Facility - PassedSubstation K 3.50 3.40 11.90 low Risk Facility Passed
Based on the results in Table V-6, the existing security and resiliency measures at the CoveredDistribution Facilities are sufficient to effectively manage the identified risks of physical attack,theft, and vandalism. Furthermore, as discussed in Section VI, planned upgrades to improvesecurity mitigation measures are being considered for these sites.
VI. DISTRIBUTION FACILITIES UPGRADE/REPLACEMENT PLANS (STEP 1C) Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, PWP has determined that for the Covered Distribution Facilities that are subject to PWP's control, the existing mitigation measures do effectively reduce the risk of a physical security attack. This section of thePlan briefly describes the proposed additional upgrade and/or replacement projects for each of the Covered Distribution Facilities and provides updates to the previously recommended upgrade projects.
Below, in Table Vl-1, is an update to the list of proposed upgrades from PWP's 2021 Physical Security Plan.
Table Vl-1: 2021 Security Mitigation Project Update
# Facility
Name
Project Status
(as of
07/20/2026)
Scope of Project Scope Update
(as of 07/20/2026)
1 Substation J Completed. 1. Enhance lighting system and remote surveillance
2. Add a keypad entry to control
house
3. Add lights point upward to
distract attackers
4. Enhance fencing and lighting
at the southwest corner of the
facility
1. Lighting added.2. Not found to be needed.3. Not found to be needed.4. Not found to be needed. 2 Substation F Completed. 1. Enhance lighting system and remote surveillance
2. Enhance or add more
padlocks to the facility gates
3. Enhance the fences at the
west side of the facility
4. Add the privacy screens
wherever missing
1. Lighting added.
2. Double chained facility gates
completed 6/2021.
3. Added barb wires on top of west
side wall, completed 10/2022.
4. Privacy screens added,
completed 10/2022.
3 Substation K | Completed. 1. Enhance lighting system and remote surveillance
2. Control/trim vegetation on
the west side of the facility
3. Enhance the fencing of
existing walls at the west side
of the facility
1. Lighting added.
2. Vegetation trimmed, completed
06/24/2021.
3. Barb wire has been added.
completed 9/2021
PWP Physical Security Plan - 2026 Update
19 The following is a list of proposed security enhancement projects sorted by facility. In Table Vl-2, all the previously determined Covered Distribution Facilities are included. These projects mainly aim toreinforce the existing security at the stations by doing the proper maintenance to better utilize theexisting security measures in place, we also plan to seal any unused gates to prevent unauthorized entrance to the sites, and to secure any tools in case they would present an opportunity to assist any intruder.
Table Vl-2: Security Mitigation Projects
#
1 2
3 Facility
Name
Estimated
Completion for
Proposed
Projects/Schedule
Scope of Project
Substation JSubstation F
FY2027 - FY2028
FY2027 - FY2028
1. Camera cleaning schedule
1. Seal unused gates.
2. Chain up ladders when not in
use.
3. Camera cleaning schedule
Substation K FY2027 - FY2028 1. Camera cleaning schedule
2. Repair barbed wire
VII. INDEPENDENT EVALUATION AND RESPONSE (STEP 2)
A. REQUIREMENTS FOR A 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. Agovernmental entity can select as the third-party reviewer another governmental entity within the same political subdivision, so long as the entity has the appropriate expertise, and is not a division of the POD 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 appropriatephysical security expertise, which means that it meets at least one of the following: (1) anentity or organization with at least one member who holds either an ASIS InternationalCertified Protection Professional (CPP) or Physical Security Professional (PSP) certification; (2) an entity or organization with demonstrated law enforcement, government, or military physical security expertise; or (3) an entity or organization approved to do physical securityassessments by the CPUC, Electric Reliability Organization, or similar electrical industryregulatory body.
PWP Physical Security Plan - 2026 Update
20 B. IDENTIFICATION OF THIRD-PARTY REVIEWER
PWP has selected Radian Generation as its Third-Party Reviewer. Radian Generation has staffmembers who qualify to conduct security plan reviews per requirements and qualifications stated above.
The independent review was conducted by the Senior Compliance and Risk Manager at Radian Generation. The reviewer has more than three years of experience managing and supporting compliance and risk programs, including the review of program documentation, risk assessments, internal controls, and mitigation activities.
C. PUBLIC RESULTS OF THIRD-PARTY EVALUATION
An independent evaluation was conducted by the Senior Compliance and Risk Manager at Radian Generation. Radian found the assessment methodology to be sufficient and the results to be accurate and consistent with good industry practices for physical security of criticalinfrastructure.
D. PWP RESPONSE
PWP accepts the evaluation results provided by the independent third-party evaluator at RadianGeneration.
VIII. VALIDATION (STEP 3)
A. SELECTION OF A QUALIFIED AUTHORITY
PWP selected the Pasadena Police Department (PPD) as the qualified authority by contacting and screening various sections within the department to find a suitable candidate. The PPD assignedstaff to review and validate this Plan. The selection was based on the PPD staff's expertise and knowledge of physical security and security based environmental design.
B. RESULTS OF THE QUALIFIED AUTHORITY REVIEW
PWP and PPD staff toured 12 out of 12 facilities and conducted inspections of current physical security measures and designs. The inspection included the current configuration of securitycameras, fencing, ingress and egress points and overall security design.
PPD validated the Physical Security Plan and provided minor recommendations to completerepairs to enhance existing fencing, establish periodic camera cleaning, and seal any unnecessarygates for each of the Covered Distribution Facilities.
C. PWP RESPONSE TO THE QUALIFIED AUTHORITY REVIEW
PWP Physical Security Plan - 2026 Update
21 PWP accepts PPD's recommendations and is currently in the process of implementing them. A list of recommended enhancements is provided in Section VI.
IX. NARRATIVE DESCRIPTIONS FOR PHYSICAL SECURITY PLAN
The CPUC order has additional requirement that the utility mitigation plans must include- a detailed narrative explaining how the utility has:
A. An asset management program to promote optimization and quality assurance for tracking and locating spare parts stock, ensuring availability and the rapid dispatch ofavailable spare parts; B. A robust workforce training and retention program to employ a full roster of highlyqualified service technicians able to respond to make repairs in short order throughout a utility's service territory using spare parts stockpiles and inventory; and, C. A preventative maintenance plan for security equipment to ensure that mitigation measures are functional and performing adequately.
A. ASSET MANAGEMENT PROGRAM
Distribution Substation physical security is a growing concern for many utilities because each of thedistribution substations is the heart of a service area of the utility. To effectively secure substations,PWP needs visibility and control over all assets at each distribution substations.PWP currently utilizes an asset management application. This software solution for achieves assetperformance management objectives and provides PWP with a focused solution for riskmanagement, predictive maintenance and other asset management activities that maximize equipment lifetimes. PWP also utilizes a separate warehouse inventory management system. PWP is currently developing a new asset management system Enterprise Asset Management (EAM) that will replace the current system for asset management and scheduling for maintenance of PWP'sequipment.
This asset management program helps PWP in tracking and locating spare parts stock, ensuring availability and the rapid dispatch of available spare parts of substation security equipment.
Having an informed understanding of the performance, configuration, and capabilities of each substation (and the supported feeders) across the complete lifecycle of PWP assets will improve notonly our operational awareness but each substation's security. The asset management program helps PWP identify the risks earlier for better asset maintenance and replacement cycles.
PWP monitors the operational condition of the asset management program activities includingactivities related to substations and their security systems and does timely repairs if a problem occurs. The security systems are upgraded as technology improves using the latest securitystandards based on the assessment and recommendations of security experts. A PWP informationsecurity officer administers the security systems plan that includes backups, staff training, and useradministration.
B. WORKFORCE TRAINING AND RETENTION PROGRAM
PWP Physical Security Plan - 2026 Update
22 One key role of the City of Pasadena hluman Resources Department (HR) is to help PWP find the qualified workers we need. HR offers services that may include electronic job orders and job fairs, use of private interview space, background checks and customized screening, and regular referrals of qualified candidates. City of Pasadena works mainly with Government Jobs to find diverse candidates - such as youth, older workers, individuals with disabilities, and other untapped sources of workers.The following paragraphs summarize Recruitment, Training and Retention Activities and Programs as conducted by the City of Pasadena.
Recruitment
The following are the most common steps taken by City of Pasadena during the hiring process of new employees. It is a step-by-step process for hiring a new employee, whereby PWP identifies itstalent needs, recruits from its talent pool and eventually hires the most qualified candidates.
1. Identify the hiring need
2. Write/Update the job description
3. Advertise and Recruit the Position4. Review Applications and Initial Screening5. Interviews, Applicant Assessment and Selection
6. Background and Reference checks
7. Hiring Best Qualified Candidate(s)
Training, Education and Up-Skilling
Building the skills and competencies of PWP workforce is essential to ensuring the swift and effectiveresponse to make (emergency) repairs in short order throughout PWP's service area using available spare parts and inventory. PWP recognizes that training for individuals must align with the needs ofits business in the electric industry. Here are several ways that PWP supports this need for training toits workforce:
Provides access to training and education programs for all employees. The programs are available through universities, colleges and trade or technical schools; LA Trade Tech through the Apprenticeship Program is a good example.Offers tuition reimbursement to qualified programs and certifications (not covered in programs mentioned above in the previous point) to further their education by sharing, or in some cases, covering the expenses.
Provides a formally approved apprenticeship Programs in Dispatching,Electronics/communications, Electrical/Meter Test, Electrical Construction and ElectricalDistribution for interested staff to become a Test Technician or Electrical Mechanic orElectrical Distribution Mechanic. The Power Plant established a new apprenticeship program that attracted hundreds of interested applicants. All apprenticeships are State certified/Union certified.
New employees are offered shadowing and cross training with a mix of instruction and onthe-job training.
PWP provides updated procedure manuals/desk reference materials/task manuals for key positions and job aids.
•
PWP Physical Security Plan - 2026 Update
23 • PWP offers two Leadership training through SCPPA, Linkedin Learning, and internal City trainings
Retention
The success or failure of any organization is increasingly determined by its ability to keep its best people. Therefore, building the skills and competencies of PWP workforce may not be enough toretain these highly skilled employees. To overcome this obstacle, PWP took tangible steps in that direction:
Produce and update the existing succession plan (career plan) to provide a clear path for career development and advancement.Continuously adjust employee compensation to ensure competitiveness with comparablepositions across the electric industry. PWP also offers extra incentive (pay) for certifications (crane operators/welders) for skills that are above job duties but benefit the utility.PWP periodically recognizes outstanding employees and offer awards/certificates of appreciations.
Provide a constructive annual performance evaluation that highlights achievements andgoals for individual development.
Provides (refresher) training services to incumbent workers and developing on-the-job and workplace trainingSupporting employee retention by offering services such as mentoring programs toindividuals engaged in training C. PREVENTATIVE MAINTENANCE PLAN
Time-based Preventive Maintenance
PWP's time-based preventive maintenance approach involves setting up a schedule to perform regular inspections on pieces of equipment, especially those that would have a severe impact on distribution in the event of a breakdown. Currently, PWP performs monthly inspections of all electrical facilities. The monthly process involves inspecting equipment and substation physicalsecurity integrity including:
Gate access
• Perimeter fencing
Housekeeping and landscaping
• Bonding of equipment
Wire tray gates
Security lighting and cameras
• Station service automatic throw-over switch
-ENDPWP Physical Security Plan - 2026 Update
24