Agenda packet — Roseville City Council, December 7, 2022 (part 4 of 8)

Form Number 79-756
March 2021
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
subject to the conditions noted below.

MODIFICATION TO NGSA AND EXHIBITS
NATURAL GAS SERVICE AGREEMENT (Continued)

BILLING
billing month.
information may be changed by Customer or Nominating Marketer by directly contacting PG&E. should be directed by Customer to PG&E using the addresses specified in Exhibit C.

COMMUNICATIONS

12. Communications about routine operations such as start-ups, shut-downs, gas nominations and scheduling,

13. Formal communications concerning this NGSA shall be in writing. Formal communications are those for anything other than routine operations. Formal communications include, modifications to rate schedules, nominating marketers, and contract quantities. Formal communications are to be delivered to the appropriate address, as specified in Exhibit D. Either Party must designate by written notice any change of address to which formal communications should be sent.

14. PG&E will bill Customer at the applicable rate(s) set forth in Exhibit A for natural gas service during the

15. PG&E will initially send Customer's monthly billings to the address specified in Exhibit D. Customer may request a change to the mailing address by directly contacting PG&E. specified in Exhibit B if there are changes in the equipment or operations at Customer's premises. Such changes must be consented to by the other party and a modified Exhibit B must be executed by both Parties. Such revisions will take effect as soon as they are processed by PG&E, unless Customer requests a later date. a later date. Revisions to Nominating Marketer and Nominating Marketer ID Numbers on Exhibit C and Formal Such revisions will take effect as soon as they are received and processed by PG&E, unless Customer requests Communications contact and mailing address on Exhibit D must be requested in writing. All other revisions to Exhibit C or D can be changed by Customer directly contacting PG&E. Nominating Marketer contact

8. Revisions or modifications to this NGSA or its incorporated exhibits must be agreed to, by both Parties,

9. Revisions to Exhibit A:

11. Revisions to Exhibit C or D: Customer may request revisions to Exhibit C or D at any time.

10. Revisions to Exhibit B: Customer or PG&E may request to adjust the contract quantities both Parties, a change from one rate schedule to another rate schedule may only be made once every twelve (12) months. Such revisions must be agreed to by both Parties. Unless otherwise agreed to by both parties, revisions will then take effect on the first day of the calendar month that occurs at least thirty (30) days after the request for the revision and remain in effect for a minimum of twelve (12) months. Negotiated provisions as specified in Exhibits A.2 or A.EG-NEG, if applicable, will be revised as specified in that exhibit. only be made as specified in the provisions of the applicable rate schedule(s). Unless mutually agreed to by A substitution of one rate schedule(s) for other rate schedules may Transp.ID #

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7180792
Form Number 79-756
March 2021
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
consent shall not be unreasonably withheld. Any successor to or transferee or assignee of the rights of a and conditions of this NGSA to the same extent as though such successor, transferee or assignee were an original Party. Assignment of this NGSA shall not release the assigning Party from any of the obligations under this NGSA unless such a release is agreed to in writing by the other Party and the assignee.

Notwithstanding the above, assignment of the entire interest and obligations of PG&E hereunder may be made to a parent or Affiliate of PG&E, or to an entity succeeding to all or substantially all of the business properties and assets of PG&E, following written notice to Customer and without obtaining the written consent of the Customer.

16. This NGSA shall not be assigned by either Party without the written consent of the other. Such

ASSIGNMENT
NATURAL GAS SERVICE AGREEMENT (Continued)
only under the provisions of Section 1702 of the Public Utilities Code. Each Party shall be entitled to recover reasonable costs, including attorney fees, to collect payment for services previously performed or other amounts due and owing under this NGSA.
the obligations of the Parties are subject to all valid laws, orders, rules, and regulations of the authorities having jurisdiction over this NGSA (or the successors of those authorities).

20. This NGSA shall be interpreted under the laws of the State of California, excluding any choice of law rules which may direct the application of the laws of another jurisdiction. This NGSA and

19. The waiver by either Party of any breach of any term, covenant or condition contained in this NGSA, any waiver of any incident of breach or default constitute a continuing waiver of the same. or any default in the performance of any obligations under this NGSA, shall not be deemed to be a waiver of any other breach or default of the same or any other term, covenant, condition or obligation. Nor shall understandings between them regarding the gas service to be provided under this NGSA are set forth or referenced in this NGSA. No agreements, representations, memoranda, or any other form of communication, written or oral, exchanged before the signing of this NGSA (other than PG&E's tariffs), shall be grounds for altering or interpreting the terms of this NGSA.

18. This NGSA does not change the obligations, restrictions or rights contained in other agreements between Parties unless expressly indicated in this NGSA. Customer and PG&E agree that all

21. Complaints against PG&E arising out of this NGSA may be asserted or filed and shall be enforced

22. Nothing in this NGSA shall be construed to create any duty to, any standard of care with reference to, or any liability to any third party.

Party, whether by voluntary transfer, judicial sale, foreclosure sale, or otherwise, shall be subject to all terms

EXCLUSIVE NATURE AND INTERPRETATIONS

17. With the exception of the CPUC-approved tariff and rule changes as provided in paragraph 27, and for changing contact names, mailing addresses, e-mail addresses, phone and fax numbers as provided for in paragraphs 8, 11, and 15, no subsequent modification or amendment of this NGSA or of any of its exhibits shall be effective unless in writing, and accompanied by a Natural Gas Service Agreement Modification Revised Exhibits Form (Form No. 79-757) signed by a duly authorized representative of each Party.

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Transp.ID # 7180792
Form Number 79-756
March 2021
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
remedied with all reasonable dispatch shall not require the settlement of strikes or lockouts when such course is inadvisable in the discretion of the Party having the difficulty. a. It is understood and agreed that the settlement of strikes or lockouts shall be entirely within the discretion of the Party having the difficulty, and the above requirement that any force majeure shall be routine maintenance and repairs of machinery and lines of pipe, operational flow orders, emergency flow orders, or diversion orders in accordance with PG&E Gas Rule 14, financial considerations, or the unavailability of upstream or downstream transportation or supply. b. It is understood and agreed that "force majeure" as used herein shall not include scheduled and in no event exceed an amount equal to any applicable pro rata charges for the period during which the services that the provisions hereof shall not apply to damages caused by willful misconduct, fraudulent conduct or or facilities are affected by the mistake, omission, interruption, loss, delay, error or defect; provided, however, service or losses of gas pursuant to this Agreement, PG&E’s gas Rules or rate schedules. The liability of PG&E for any curtailments, interruptions of service, or gas losses otherwise arising out of mistakes, omissions,

23. PG&E shall have no liability to Customer, or any assignee thereof, for any curtailments, interruptions of interruptions, delays, errors or defects in any of the gas services or facilities used or furnished by PG&E shall violations of law by PG&E.
damages, whether in contract or tort (including negligence) or otherwise, for any breach, actions, or inactions

24. No Party under this Agreement shall be assessed any special, punitive, consequential, incidental, or indirect arising from, out of, or related to this Agreement.
disturbances, acts of the public enemy, wars, blockage, insurrection, riots, epidemics, landslides, lightning, earthquakes, fires, storms, floods, high water, washouts, civil disturbances, explosions, breakage or accident to machinery or lines of pipe, the necessity for making non-routine repairs or non-routine alterations to machinery or lines of pipe, freezing lines of pipe, acts of civil or military authority (including, but not limited to, courts, or administrative or regulatory agencies), and any other cause, whether of the kind herein enumerated or otherwise, not within the control of the Party claiming suspension and which, by the exercise of due diligence, that Party is

FORCE MAJEURE
unable to prevent or overcome.

25. In the event either Customer or PG&E is rendered unable, wholly or in part, by its obligations under this Agreement, it is agreed that, upon such Party giving notice as soon as practicable in writing (or as soon as practicable by facsimile or telephone if confirmed in writing within seventy-two (72) hours) but in no event delivered to the other Party later than five (5) business days after the onset of the condition, then the obligations of the Party giving such notice, so far as they are affected by such shall be suspended during the continuance of the effects of the cause; provided that such notice shall give the payment for services rendered prior to its inception.
other Party reasonably full particulars of such
performance hereunder; and provided that the Party subject to such possible with all reasonable dispatch; and further provided that no The term "force majeure," as employed herein, shall mean acts of God, strikes, lockouts or other industrial force majeure,
force majeure
force majeure to carry out
force majeure shall remedy it so far as
force majeure shall be cause for delay in the
force majeure, including the circumstances preventing or delaying NATURAL GAS SERVICE AGREEMENT (Continued)

26. Transp.ID #

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7180792
Form Number 79-756
March 2021
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A

REGULATORY

26. Customer shall not take any action which may subject PG&E's gas operations to the jurisdiction of the Federal Energy Regulatory Commission (FERC) or any successor to the FERC. Any such action is cause for the immediate termination of this NGSA.

27. This NGSA shall at all times be subject to any changes or modifications the CPUC may direct from time to time in the exercise of its jurisdiction. Such changes or modifications may be to this NGSA or to PG&E's applicable tariff schedules and rules.

NATURAL GAS SERVICE AGREEMENT (Continued)
Dominick Casey Eric Linkugel
AGREED TO BY:
(For Customer) (For PG&E)
Sr. Mngr., Customer Success Management
(Signature Date) (Signature Date)
City Manager
(Please print or type) (Please print or type)
Attachments: Exhibits: [X] Exhibit A.EG - Rates and Term [X] Exhibit B - Contract and Quantities
[X] Exhibit C - Scheduling and Operations Data
[X] Exhibit D - Customer Contact and Billing Address
Tariffs: G-EG,G-BAL,G-SUR G-NR1
Gas Rules 1, 2, 9, 10, 11, 12, 14, 17, 21, 29
(Signature) (Signature)
Name of Authorized Representative Name of Authorized Representative (Title) (Title)
Transp.ID #

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7180792
Form Number 79-756
March 2021
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
Transp. ID No: 7180792
(date), with an initial term
The exemptions are specified in Schedule G-SUR. 1
II. NONCORE RATE SCHEDULES:
notice to PG&E. Termination or revision by the Customer will take effect on first day of the calendar month that occurs at least thirty (30) days after notification, unless otherwise agreed by PG&E. Per gas Rule 12, certain noncore Customers are prohibited from reclassification to core service. If this Exhibit A.EG has been revised, indicate the effective date of the latest revision here: (revision effective date).

IV.
1 FRANCHISE FEE SURCHARGE EXEMPT:
[Yes]
is a political subdivision of the state of California.

Enter Yes in box if Customer's usage is exempt from charges under Schedule G-SUR because Customer Transportation: Customer elects to receive noncore natural gas transportation service under the terms and authority to make daily gas nominations in Exhibit C, unless G-EG is taken in conjunction with a core rate schedule is provided under the terms and conditions of Schedule G-NT. Please list all Nominating Marketers having the conditions of Schedule G-EG. All noncore natural gas transportation that does not qualify under Schedule G-EG and gas is provided by a Core Procurement Group.

This Section must be completed if Customer is taking transportation and/or procurement service under a core rate schedule in conjunction with Schedule G-EG.

III. CORE RATE SCHEDULE(S):

Please list all Nominating Marketers having the authority to make daily gas nominations in Exhibit C. [X] Non-PG&E supplied gas under Schedule G-NR1 (PG&E transportation service only).

Procurement service cannot be supplied by a Core Procurement Group. [ ]
This option is only available to a facility that 1) qualifies as a cogeneration facility pursuant to California Gas supplied by a Core Procurement Group in conjunction with Schedule Public Utilities Code Section 218.5 and 2) has a rated generation capacity of less than five-hundred kilowatts (500 kW) and 3) does not have a generation usage exceeding 250,000 therms per year.

If gas is supplied by a Core Transport Agent (CTA), indicate the CTA Group name and number in Special Billing instructions
2 [ ]
Public Utilities Code Section 218.5
Enter Yes in box if this box if Customer's facility qualifies as a cogeneration facility pursuant to California If facility qualifies as cogeneration facility, check box even if previous exempt box is also checked 2 CUSTOMER NAME: CITY OF ROSEVILLE
EXHIBIT A.EG - RATES AND METERING INFORMATION
I. TERM:

The provisions specified in this Exhibit A.EG will take effect on of twelve (12) months. After the initial term, these provisions will continue on a month-to-month basis until terminated or revised by Customer or by PG&E (as specified in the NGSA), upon thirty (30) days written 01/01/2023
Exhibit A.EG

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Form Number 79-756
Advice 2784-G
Revised November 2006
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A March 2021 EXHIBIT A.EG - RATES AND METERING INFORMATION
CUSTOMER NAME: CITY OF ROSEVILLE Transp. ID No: 7180792 GAS METER INFORMATION:

Metering and service point information will be completed and updated by PG&E, as needed.

V. METERING INFORMATION:
5927421404 61914914 Core Trans NO NO
6583225856 61914910 Noncore Trans YES YES
Service
Point No.

Badge
Number
Badge
No. Gen. Load
only Serve
Cogen
Load
Meter Submeter Does Meter Is Gen
Noncore
Core or
or Dist.

BB or Trans.

Meter Serves
5 "Yes" indicates the meter serves only electric generation (EG). "No" indicates the meter serves only nongeneration Load. "Both" indicates the meter serves both generation and non-generation load. 6 "Yes" indicates that the generation facility qualifies as a cogeneration facility pursuant to California Public Utilities Code 218.5, otherwise, "No" will be entered. Gas that is used for generation through this meter is exempt from G-SUR charges. The exemption is specified in Schedule G-SUR.

NET ELECTRIC OUTPUT METER INFORMATION IF GAS METER SERVES BOTH Meter
Badge Number
Net Electric Output
Service Point No.

Submeter
Badge Number
GENERATION AND NON-GENERATION LOAD: Metering and service point information will be completed and updated by PG&E, as needed. Customer-Owned metering is at PG&E's Sole Discretion.

The Net Electric Output meter is owned by: (indicate below) Customer or by PG&E
(indicate by placing a check in the appropriate space). [ ]
3 2
Meters for new NGSAs or meters added to existing NGSAs must serve either 100% core or 100% noncore load.

Completed only if a subtractive meter to the primary meter exists for service point number.

If meter serves generation load and the otherwise-applicable rate is a core rate schedule or the Customer is receiving procurement from a Core Procurement Group, "Core" will be entered. 4 This area is used to indicate if the meter is to be billed at the Backbone Level Rate ("BB") under schedule G-EG. If meter serves noncore load that is not billed at the Backbone Level Rate, the designation will be PG&E-Owned. [ ]
"Trans" or "Dist" to indicate whether meter is connected to the Transmission or Distribution System respectively If meter serves core load, the designation "Dist" is used.

Customer-Owned: Monthly meter reads will be provided by:

Exhibit A.EG

Page 2 of 3 ends

Form Number 79-756
Advice 2784-G
Revised November 2006
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A March 2021 2 3 4 5 6
Transp. ID No: 7180792
VII.
(4x200 kW microturbines) Capstone C800
No NGOM - meter# 61914914 serves the boilers
Heat Rate should be validated with customer if using the heat rate to SPECIAL BILLING INSTRUCTIONS:
bill G-EG volumes
VI.

EXHIBIT A.EG - RATES AND METERING INFORMATION
CUSTOMER NAME: CITY OF ROSEVILLE
HEAT RATE AND GENERATOR CAPACITY:

Enter Generator Capacity for all Customers. The Annual Average Heat Rate must be completed if the electric generation equipment does not have a separate PG&E installed gas meter. All delivered gas that does not qualify for Schedule G-EG will be billed at the otherwise applicable rate. The Annual Average Heat Rate (kW)
(BTU/kWh)
800
10,300
Generator Capacity
Annual Average Heat Rate
can be adjusted by PG&E based on actual recorded values. ities
Exhibit A.EG

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Form Number 79-756
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A March 2021 CUSTOMER NAME: CITY OF ROSEVILLE Transp. ID No: 7180792

EXHIBIT B - CONTRACT QUANTITIES
may be adjusted if Customer can document to the satisfaction of PG&E that changes in Customer's operations warrant a modified MDQ. The MDQ, plus in-kind shrinkage, will be the maximum amount of gas that MDQ is based on the historical maximum single day use at the facilities served under the NGSA. The MDQ 115 decatherms.

Customer will be allowed to deliver into PG&E's service territory on any day.

For purposes of this Exhibit, quantities (specified in decatherms) are identified by column as follows:
shrinkage on the PG&E system.

Column B. Total Monthly Quantities (TMQ) of
Column A. Total Monthly Quantities (TMQ) of
The Average Daily Quantity (ADQ) is equal to the TMQ in Column A plus the TMQ in Column B, divided Column C. Number of Operating Days in the Month
All quantities represent volumes delivered to Customer's premises, and do not include in-kind by the Operating Days in Column C.

Column A
Core Noncore
(Dth) (Dth)
Column C
Operating Days
In Month
Column B
January : 61 2,847 31
February : 61 2,847 28
March : 61 2,847 31
April : 61 2,847 30
May : 61 2,847 31
June : 61 2,847 30
July : 61 2,847 31
August : 61 2,847 31
September : 61 2,847 30
October : 61 2,847 31
November : 61 2,847 30
December : 61 2,847 31
Customer must designate a Maximum Daily Quantity (MDQ) for all service provided under the NGSA. The

MAXIMUM DAILY QUANTITY
MAXIMUM DAILY QUANTITY (MDQ):

II. MONTHLY AND ANNUAL CONTRACT QUANTITIES
This Exhibit B was modified on 1/1/2023 (Date)
Core Service
Noncore Service

Page 1 of 1 ends

March 2021
Advice 4350-G-A/6050-E-A
Form 79-756, Exhibit B
Automated Document, Preliminary Statement Part A
_______________________________________________
CUSTOMER NAME: CITY OF ROSEVILLE Transp. ID No: 7180792

EXHIBIT C - SCHEDULING AND OPERATIONS DATA
This Exhibit C is effective on
NGSA is terminated.

I. NOMINATING MARKETER:

NOMINATING MARKETER : 1 MARKETER ID NUMBER: 1021
CITY/STATE/COUNTRY: San Diego, CA
CONTACT: Lisa Kinsey
Customer can check one or more of the boxes below to indicate the appropriate authorization:

CO. NAME: Shell Energy North America (US), L.P.

ADDRESS: 4445 Eastgate Mall, Suite 100
[X] Customer authorizes this Nominating Marketer to execute monthly imbalance trades, as specified in Schedule G-BAL. 2
[ ] This Nominating Marketer cannot view the contract quantities indicated in Exhibit B. [ ] This Nominating Marketer cannot have access to gas metering data.

ALTERNATE NO.: (858) 320-2656
(858) 526-2127
92121-
FAX NO.:

PHONE NO.:

ZIP CODE:

COMPANY NAME: PACIFIC GAS and ELECTRIC COMPANY
PG&E GAS SCHEDULING & OPERATIONS:

ADDRESS/CITY/STATE: 77 Beale St. Room 1645 San Francisco, CA 94106 ALTERNATE NO.: (415) 973-3216 (24 hr.)
III.

CONTACT: Transportation Coordinator PHONE NO.: (415) 973-2424 FAX NO.: (415) 973-0649

CUSTOMER OPERATING CONTACT
Nominating Customer ID Number:

II.
(if Customer makes gas supply nominations)

CITY OF ROSEVILLE
ADDRESS: 5051 West Park Drive
CO. NAME:

CONTACT:

ALTERNATIVE NO.:

Jason Fick (916) 746-1940
(916) 223-3476
CITY/STATE/COUNTRY: Roseville, CA ZIP CODE: 95747
PHONE NO.:

FAX NO.:

Note: OFO, EFO and Curtailment notification will only be sent to the Rule 14 Notification E-mail addresses specified on Exhibit D. 01/01/2023 (date), and will remain in effect until it is revised or the Customer shall list the Nominating Marketer(s) having the authority to nominate gas deliveries to PG&E.

All listed Nominating Marketers will be allowed access to gas metering data and Exhibit B Contract quantities, unless otherwise indicated by Customer by checking the appropriate boxes below each Nominating Marketer.

Customer can also designate one Nominating Marketer as having the authority to trade monthly imbalances on Customer’s behalf by checking the appropriate box below. 2 1 Communications by a Nominating Marketer shall be binding on Customer and shall prevail if there is any conflict behalf of Customer for as long as the Nominating Marketer is listed in the Exhibit C of Customer’s NGSA, unless with information regarding nominations or receipt of gas from Customer. The Nominating Marketer shall act on a formal written notification is received by PG&E that such arrangement no longer exists.

Customer remains responsible for any and all charges associated with Schedule G-BAL and Rule 14.

Balancing Aggregation Agreement, Exhibit A, Form 79-869 with a Nominating Marketer or other third-party service provider, Only one Nominating Marketer can be granted authority to trade imbalances. Unless Customer has executed a Noncore Form Number 79-756
March 2021
Exhibit C - Page 1 of 1
Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
_________________________________________________
Customer Name: CITY OF ROSEVILLE Transp. ID No: 7180792 NGSA. Customer can only designate one Formal Communications Address.

NGSA is terminated. If this Exhibit D has been revised, indicate the effective date of the latest revision here: 10/25/2022 (revision effective date).

Directions: Check the type of communication for each of the following addresses where applicable. Any of This Exhibit D is effective on 1/1/2023 (date), and will remain in effect until it is revised or the the names or addresses listed below may be changed upon notification from Customer as specified in the

EXHIBIT D - CUSTOMER CONTACT AND BILLING ADDRESSES
[X] BILLING ADDRESS [ ] IMBALANCE STATEMENT ADDRESS
CO. NAME:

ADDRESS:

CONTACT: Jason Fick
ALTERNATE NO.:

CITY/STATE/COUNTRY: Roseville, CA USA ZIP CODE:

CITY OF ROSEVILLE
5051 West Park Dr
95747-
PHONE NO.:

FAX NO.:

ZIP CODE:

PHONE NO.:

FAX NO.:

CO. NAME:

ADDRESS:

CITY/STATE/COUNTRY: Roseville, CA USA
CONTACT: Tracie Mueller
ALTERNATE NO.: (916) 259-6693
(916) 774-5688

CITY OF ROSEVILLE
5051 West Park Dr
[X] FORMAL COMMUNICATION
[ ] BILLING ADDRESS
[X] IMBALANCE STATEMENT ADDRESS
95747-
OFO/EFO NOTIFICATIONS Please provide at least one e-mail address - Maximum of 5

NAME E-MAIL ADDRESS
JASON FICK [email protected]
Pacific Gas and Electric Company
ATTENTION:

CITY/STATE/ZIP CODE:

DIVISION:

ADDRESS:

PG&E FORMAL COMMUNICATIONS:

TO PG&E:

Auburn, CA 95603
343 Sacramento St

SACRAMENTO
BES Customer Relationship Manager
Exhibit D
March 2021
Form Number 79-756

Page 1 of 1 ends

Advice 4350-G-A/6050-E-A
Automated Document, Preliminary Statement Part A
_________________________________________________

COUNCIL COMMUNICATION
CC #: 2431
File #: 1002-04
Title: Campus Oaks Well Site – Acceptance of Irrevocable Offer of Dedication of Land Contact: Janice Gainey 916-774-5535 [email protected] Meeting Date: 12/7/2022
Item #: 6.15.

RECOMMENDATION TO COUNCIL
It is recommended that the City Council take the following action:

1. Adopt the attached resolution accepting the in fee irrevocable offer of dedication of Lot 24 as offered on the Large Lot Final Map of Campus Oaks recorded in Book DD of Maps,

Page 47 ends

2. Authorize the City Manager to execute any and all other documents as may be necessary to effect the recordation and enforcement of this acceptance.

3. Authorize the City Clerk or her designee to record the Resolution of Acceptance at the Recorder’s Office of Placer County.

BACKGROUND
The City is actively implementing an Aquifer Storage and Recovery (ASR) Program, which involves construction of ASR wells capable of both water injection and groundwater extraction.

The City is preparing a Request for Proposals (RFP) for drilling of both the Campus Oaks (well 13) and Misty Wood (well 19) ASR wells. Prior to the City entering into a construction agreement, the City must first take ownership of the Campus Oaks well site property. The Misty Wood well site property is already owned by the City.

On December 16, 2015, the City approved the Large Lot Final Map of Campus Oaks and it was subsequently recorded on December 23, 2015, in Book DD of Maps, Page DD in the office of the Recorder of Placer County. On the final map, Lot 24 was irrevocably offered in fee to the City as a site for a future well site and the City rejected the offer, but reserved the right to accept it at a later date. Under the Subdivision Map Act, offers of dedication rejected by the legislative body remain open and can be accepted by resolution at a later date.

Staff has determined that it would benefit the City to take ownership of the Campus Oaks well site property in order to facilitate the completion of the Campus Oaks Well project, thereby providing additional water supply reliability within the City. Therefore, staff recommends that the City accept the in fee irrevocable offer of Lot 24, the future site of the Campus Oaks Well site.

FISCAL IMPACT
There is no fiscal impact to the City associated with this approval.

ENVIRONMENTAL REVIEW
Council approval of the resolution accepting the in fee irrevocable offer of dedication is an action that is subject to CEQA. Project level CEQA compliance for the project was accomplished with the preparation of the Hewlett Packard Master Plan EIR, adopted in 2015 (SCH#95112022), and subsequent CEQA addendums for the Hewlett Packard Campus Oaks Master Plan. The proposed well was evaluated in the Aquifer Storage and Recovery (ASR) Program Draft and Final EIR certified in 2012 (SCH 2009072018). Because the action is consistent with the project evaluated in the previously certified and adopted CEQA documents, no new affects would be expected to occur and all applicable mitigation measures from the CEQA documents will be implemented. As such, no additional CEQA action is required at this time.

CITY COUNCIL STRATEGIC PLAN/OVERARCHING GOALS
Goal F - Invest in well-planned infrastructure and growth Respectfully Submitted,
Janice Gainey, Senior Engineer
Richard Plecker, Environmental Utilities Director
_____________________________
Dominick Casey, City Manager
ATTACHMENTS:

Description
Resolution 22-444
Exhibit A - Legal Description
Exhibit B - Map
Large Lot Final Map of Campus Oaks
RESOLUTION NO. 22-444
ACCEPTING THE IN FEE IRREVOCABLE OFFER OF DEDICATION OF LOT 24 AS

OFFERED ON THE LARGE LOT FINAL MAP OF CAMPUS OAKS, AND

AUTHORIZING THE CITY MANAGER TO EXECUTE ANY AND ALL DOCUMENTS

AS MAY BE NECESSARY TO EFFECT THE RECORDATION AND ENFORCEMENT

OF THIS ACCEPTANCE ON BEHALF OF THE CITY OF ROSEVILLE
WHEREAS, in 2015, the City Council approved a Large Lot Map for Campus Oaks and it was recorded on December 23, 2015, in Book DD of Maps, Page 47, in the office of the Recorder of Placer County; and
WHEREAS, on the final map, Lot 24 was irrevocably offered in fee to the City as a site for a future well site and the City rejected the offer, but reserved the right to accept it at a later date; and
WHEREAS, under the Subdivision Map Act, offers of dedication rejected by the legislative body remain open and can accepted by resolution at a later date; and WHEREAS, staff has determined that it would benefit the City to take ownership of the Campus Oaks well site in order to facilitate the completion of the Campus Oaks Well project thereby providing additional water supply reliability within the City; and WHEREAS, staff recommends that the City accept the in fee irrevocable offer of Lot 24, the future site of the Campus Oaks Well site.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Roseville that said In Fee Irrevocable Offer of Dedication, as described in Exhibit A and depicted on Exhibit B, is hereby accepted.

BE IT FURTHER RESOLVED that the City Manager is hereby authorized to execute any and all documents as may be necessary to effect the recordation and enforcement of this acceptance on behalf of the City of Roseville, and the City Clerk is directed to record the Resolution of Acceptance with the Placer County Recorder.

PASSED AND ADOPTED by the Council of the City of Roseville this day of , 20 , by the following vote on roll call:

AYES COUNCILMEMBERS:

NOES COUNCILMEMBERS:

ABSENT COUNCILMEMBERS:

MAYOR
ATTEST:

City Clerk
Exhibit “A”
Legal Description of the Campus Oaks Well Site Parcel
All that certain real property situated in the City of Roseville, County of Placer, State of California, situated in Section 20, Township 11 North, Range 6 East, Mount Diablo Meridian, more particularly described as follows:

ALL OF LOT 24, AS SAID LOT 24 IS SHOWN AND SO DESIGNATED ON THAT CERTAIN MAP ENTITLED “LARGE LOT FINAL MAP CAMPUS OAKS SUBDIVISION NO. PL14-0373” AND FILED FOR RECORD ON DECEMBER 23, 2015, IN BOOK DD OF MAPS AT PAGE 47, PLACER COUNTY RECORDS.

PROPERTY EXHIBIT

IRREVOCABLE OFFER OF DEDICATION
LOT 24 OF CAMPUS OAKS LARGE LOT

FINAL MAP
LOT 24
137.23'(OA)
108.48
S89°32'34"W
112.15'
S
01°0
6'19"W
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COUNCIL COMMUNICATION
CC #: 2436
File #: 0800-03
Title: Roseville Electric Utility Physical Security Plan Update Contact: Petra Wallace 916-774-5510 [email protected] Meeting Date: 12/7/2022
Item #: 6.16.

RECOMMENDATION TO COUNCIL
Roseville Electric Utility staff recommends that the City Council adopt a resolution to approve the updated Roseville Electric Utility Physical Security Plan.

BACKGROUND
City Council adopted the Roseville Electric Utility Physical Security Plan (“Plan”) on June 16, 2021 in Resolution No. 21-277. The purpose of the Plan is to meet the physical security plan requirements as defined by the California Public Utilities Commission (CPUC) Phase I Decision on Order Instituting Rulemaking Regarding the Physical Security of Electrical Corporations D.19- 01-018.

The Plan describes Roseville Electric Utility’s conformance with the industry standard set by D.19-01-018 and describes the approach that Roseville is taking to identify and protect our critical infrastructure (Covered Distribution Facilities) from physical security threats.

As recommended in the Plan adopted on June 16, 2021, Roseville is developing a design to install security cameras at the identified Covered Distribution Facilities.

FISCAL IMPACT
There is no fiscal impact associated with the Physical Security Plan. Future security improvements of facilities will be included in future budgets.

ENVIRONMENTAL REVIEW
The California Environmental Quality Act (CEQA) does not apply to activities that will not result in a direct or reasonably foreseeable indirect physical change in the environment, or is otherwise not considered a project as defined by CEQA Statute §21065 and CEQA State Guidelines §15060(c)(3) and §15378. Approval of the Roseville Electric Utility Physical Security Plan Update meets this criteria and is not subject to CEQA. No additional environmental review is required.

CITY COUNCIL STRATEGIC PLAN/OVERARCHING GOALS
Goal A - Remain fiscally responsible in a changing world Goal C - Maintain a safe and healthy community
Respectfully Submitted,
Petra Wallace, Electric Risk and Compliance Supervisor
Dan Beans, Electric Utility Director
_____________________________
Dominick Casey, City Manager
ATTACHMENTS:

Description
Resolution 22-452
Utility Security Plan REDLINE 102622
Utility Security Plan Clean 102622
RESOLUTION NO. 22-452

APPROVING THE ROSEVILLE ELECTRIC UTILITY PHYSICAL SECURITY PLAN WHEREAS, City Council adopted the Roseville Electric Utility Physical Security Plan (“Plan”) on June 16, 2021 in Resolution No. 21-277; and WHEREAS, the purpose of the Plan is to meet the physical security plan requirements as defined by the California Public Utilities Commission (CPUC) Phase I Decision on Order Instituting Rulemaking Regarding the Physical Security of Electrical Corporations D.19-01-018; and
WHEREAS, the Plan describes Roseville Electric Utility’s conformance with the industry standard set by D.19-01-018 and describes the approach that Roseville is taking to identify and protect our critical infrastructure (Covered Distribution Facilities) from physical security threats; and
WHEREAS, as recommended in the Plan adopted on June 16, 2021, Roseville is developing a design to install security cameras at the identified Covered Distribution Facilities; and
WHEREAS, the Roseville Electric Utility Physical Security Plan has been reviewed by the City Council; and
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of Roseville that said Roseville Electric Utility Physical Security Plan is hereby approved and may be submitted to the California Public Utilities Commission.

PASSED AND ADOPTED by the Council of the City of Roseville this day of , 2022, by the following vote on roll call:

AYES COUNCILMEMBERS:

NOES COUNCILMEMBERS:

ABSENT COUNCILMEMBERS:

MAYOR
ATTEST:

City Clerk

ROSEVILLE ELECTRIC UTILITY

PHYSICAL SECURITY PLAN
PUBLIC REPORT ON ROSEVILLE ELECTRIC UTILITY’S
PHYSICAL SECURITY PROGRAM FOR DISTRIBUTIONLEVEL FACILITIES July December 7, 20212022

TABLE OF CONTENTS
I. Overview ............................................................................................................................................... 44 A. Goal of Utility Security Plan ............................................................................................................ 44 B. Description of Roseville Electric Utility .......................................................................................... 44 C. Results of Utility Security Plan Assessement .................................................................................. 44 II. Background .......................................................................................................................................... 55 III. Plan Development Process ............................................................................................................ 66 A. Physical Security Principles ............................................................................................................. 66 B. Utility Security Plan Development Process ................................................................................... 77 STEP 1: Assessment/Plan Development ............................................................................................ 77 STEP 1A: Identify Covered Distribution Facilities .............................................................................. 77 STEP 1B: Perform Risk Assessment ....................................................................................................... 77 STEP 1C: Develop Mitigation Plan ...................................................................................................... 77 STEP 2: Independent Review .............................................................................................................. 88 STEP 3: Validation ................................................................................................................................. 88 STEP 4: Adoption ................................................................................................................................... 88 STEP 5: Maintenance ........................................................................................................................... 88 STEP 6: Repeat Process ........................................................................................................................ 88 IV. Identification of Covered Distribution Facility (Step 1A) ........................................................... 99 A. Identification Factors ...................................................................................................................... 99 B. Identification Analysis ................................................................................................................. 1010 V. Risk Assessment (Step 1B) ................................................................................................................ 1111 A. Methodology ............................................................................................................................... 1111 B. Mitigation Measures .................................................................................................................... 1111 C. Risk Assessment ............................................................................................................................ 1313 VI. Covered Distribution Facility Mitigation Plans (Step 1C) ....................................................... 1414 A. Covered Distribution Facility Mitigation Plan .......................................................................... 1515 VII. Independent Evaluation and Response (Step 2) ................................................................... 1717 A. Requirements for Qualified Third Party Review ....................................................................... 1817 B. Identification of Third Party Reviewer ....................................................................................... 1818 C. Public Results of Third Party Evaluation .................................................................................... 1818 D. Roseville Electric Utility Response .............................................................................................. 1818 VIII. Validation (Step 3) ...................................................................................................................... 1918 A. Selection of Qualified Authority ................................................................................................ 1918 B. Results of Qualified Authority Review ....................................................................................... 1918 C. Roseville Electric Utility Response to Qualified Authority Review ......................................... 1919 IX. Narrative Descriptions for Utility Security Plan ......................................................................... 1919 A. Asset Management Program .................................................................................................... 1919 B. Workforce Training and Retention ............................................................................................ 2019 C. Preventative Maintenance Plan ............................................................................................... 2019 D. Physical Security Event Training ................................................................................................. 2020 Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
4 I. OVERVIEW
A. GOAL OF UTILITY SECURITY PLAN
Ensuring the safety of its facilities is a top priority for Roseville Electric Utility (Roseville). Roseville prioritizes safety in all aspects of its design, operation, and maintenance practices. The overarching goal of this Utility Security Plan is to describe Roseville’s risk management approach concerning “Covered Distribution Facilities” physical security as defined by the Joint IOU/POU Straw Proposal and D.19-01-018. Appropriate consideration of resiliency, impact, and cost factors were also considered.

B. DESCRIPTION OF ROSEVILLE ELECTRIC UTILITY
Roseville Electric Utility, as the City of Roseville’s community-owned electric service, has provided reliable and affordable electric service for more than 100 years. The City of Roseville is located in Placer County, northeast of Sacramento, California along Interstate 80 and State Route 65 (38°45’9”N, 121°17’22” W), and has a population of nearly 140,000. In 2020, Roseville Electric Utility employed 153 people and served 63,507 customers, including 56,467 residential and 7,040 business customers. Roseville owns its distribution system, fifteen distribution substations (including two Receiving Substations). Roseville’s system serves an area of 43 square miles, and maintains 145 miles of overhead lines and more than 704 miles of underground lines.

C. RESULTS OF UTILITY SECURITY PLAN ASSESSEMENT
Roseville has fifteen Distribution Facilities located within its service territory meeting the definition of Distribution Facility per D.19-01-018. A Distribution Facility is defined as an electric power substation associated with the distribution system and the primary feeders for supply to residential, commercial and/or industrial loads.

All fifteen Distribution Facilities were considered and evaluated in Roseville’s Physical Security Program for Distribution Level Facilities. In order to identify which of the fifteen Distribution Substations within Roseville’s service territory provide electricity to critical loads, a thorough risk assessment was completed in Section VI. The assessment identified four “Covered Distribution Facilities” as defined by the Joint IOU/POU Straw Proposal and D.19-01-018.

After an extensive review of Roseville’s existing methodology, it was determined that the risk level for the four Covered Distribution Facilities was medium, with existing and planned mitigating measures sufficient to effectively mitigate the identified risks of a physical attack to a low/very low probability. Roseville continues to identify and assess potential risks associated with Covered Distribution Facilities and continues to apply the methodologies described in this document.

Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
5 II. 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.

At the state level, Senator Jerry Hill authored SB 699 (2014), directing the California Public Utilities Commission (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 (SED) prepared a white paper proposing a new requirement for investor owned utilities (IOUs) 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 their proposal.

In order to support the CPUC’s development of reasonable industry standards for state-level regulations of physical security, 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 Proposal1 (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, Roseville staff participated in the development of the Joint IOU/POU Straw Proposal through a CMUA working group as well as through direct meetings with the IOUs. The Joint POU/IOU Straw Proposal set out a guideline 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 determining the distribution facilities where the identified risks are not effectively mitigated through existing resilience/security measures and a process for developing a mitigation plan; (4) a process where a third party reviews the mitigation plans; (5) a document retention policy; (6) a verification process established by the POU governing board; and (7) for information sharing protocols.

1 Straw Proposal available at:
https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/R1506009- Updated%20Joint%20Straw%20Proposal%20and%20Cover%20083117%20Filing.pdf. 2 SED Response available at:
https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/Final%20Staff %20Recommendation%20for%20Commission%20Consideration%20010318.pdf.

Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
6 In early 2019, the CPUC approved Decision (D.) 19-01-018, which adopted the Joint IOU/POU Straw Proposal as modified by the SED proposal, with additional clarifications and guidance.

D.19-01-018 clarified that where there is a conflict between the Straw Proposal and the SED Proposal, then it is the rule in the SED Proposal that controls.3 The POUs generally treat CPUC safety rules for electric utility supply systems as key industry standards. This Utility Security Plan describes Roseville Electric Utility’s conformance with the industry standard set by D.19-01-018.

III. PLAN DEVELOPMENT PROCESS
A. PHYSICAL SECURITY PRINCIPLES
The Joint IOU/POU Straw Proposal seeks to support the creation of a risk management approach toward distribution system physical security, with appropriate considerations of resiliency, impact, and cost. In order to accomplish this risk-based approach, the Joint IOU/POU Straw 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 Substations, but only those that risk dictates would require additional measures.

3 D.19-01-018 at 43, 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.”).

Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
7 B. UTILITY SECURITY PLAN DEVELOPMENT PROCESS
Roseville utilized a multi-step process to develop this Utility Security Plan that is consistent with the Joint IOU/POU Straw Proposal and D.19-01-018. The intent of the proposal is to implement a risk management approach toward distribution system physical security, with appropriate consideration of resiliency, impact, and cost. In order to accomplish this risk-based approach, general principles were derived from information described and evaluated during meetings to guide the utility’s overall evaluation of Distribution Facilities. The relevant six steps of that process are the following:

STEP 1: ASSESSMENT/PLAN DEVELOPMENT
Roseville’s staff prepared a Draft Utility Security Plan through the process set forth in Steps 1A, 1B, and 1C. Please note the following principles:
 Distribution Facilities 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 of a significant attack.
 Distribution Facilities 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.
 The focus of this assessment is both physical security protection and operational resiliency on the identified critical load facilities (Covered Distribution Facilities) in which additional risk mitigation measures are required.

STEP 1A: IDENTIFY COVERED DISTRIBUTION FACILITIES
Roseville evaluated all distribution-level facilities in its service territory that are subject to its control to determine if any facility met the definition of a “Covered Distribution Facility” pursuant to the factors identified in the Joint IOU/POU Straw Proposal as modified by D.19-01-018.

STEP 1B: PERFORM RISK ASSESSMENT
For every individual “Covered Distribution Facility” identified in the Joint IOU/POU Straw Proposal as modified by D.19-01-018 pursuant to Step 1A, Roseville performed an evaluation of the potential risks associated with a successful physical attack that Covered Distribution Facilities, and whether existing grid resiliency, back-up generation, and/or physical security measures appropriately mitigate identified risks.

STEP 1C: DEVELOP MITIGATION PLAN
If there are 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 Roseville will develop a Mitigation Plan for that Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
8 Covered Distribution Facilities. The Mitigation Plan will use a risk-based approach to select reasonable and cost-effective measures that can either be security focused (e.g., walls or alarms) or resiliency focused (e.g., adequate spare parts).

STEP 2: INDEPENDENT REVIEW
Roseville’s Utility Security Plan cycle will contain the identification process, risk assessment, and Mitigation Plan development performed pursuant to Steps 1A, 1B, and 1C. This documentation in combination with the narrative description in Sections IV-VI below will constitute Roseville Electric Utility’s Draft Utility Security Plan. Each Draft Utility Security Plan is submitted to a Qualified Third Party for Independent Review. The Qualified Third Party will may then issue an evaluation that identifies any potential deficiencies in the Draft Utility Security Plan as well as recommendations for improvements. Roseville will then modify its plan to address any identified deficiencies or recommendations. The combination of the Draft Utility Security Plan, the nonconfidential conclusions of the Qualified Third Party, and Roseville’s responses to the Qualified Third Party Review will constitute Roseville Electric Utility’s Utility Security Plan.

STEP 3: VALIDATION
Roseville will may submit its Utility Security Plan to a qualified authority for review. Such entity will provide additional feedback and evaluation of Roseville Electric Utility’s Utility Security Plan and, to the extent that this entity is authorized, such entity deems the Utility Security Plan as adequate.

STEP 4: ADOPTION
Roseville’s Utility Security Plan will be presented to and adopted by City of Roseville’s Council at a public meeting.

STEP 5: MAINTENANCE
Roseville will refine and update the Utility Security on an ongoing basis as appropriate and necessary to preserve plan integrity.

STEP 6: REPEAT PROCESS
Roseville will repeat this six step process at least once every five years or sooner if circumstances dictate.

Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
9 IV. IDENTIFICATION OF COVERED DISTRIBUTION FACILITY (STEP 1A) As described in Section III, Step 1A of the Utility Security Plan process involves assessing all distribution-level facilities that are subject to the control of Roseville to determine which facilities are “Covered Distribution Facilities” subject to the need for a risk assessment. This Section describes the factors that Roseville used to evaluate its distribution facilities and the results of its evaluation.

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 in order to be applied to Roseville’s facilities. The following Table provides the Joint IOU/POU Straw Proposals Factors as modified/clarified by Roseville.

Factor Joint IOU/POU Straw Proposal Description Roseville’s Specific Approach* 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
Roseville reviewed system operations, grid
operations, and area planning to identify
any crank path or black start essential
facilities within Roseville Electric Utility’s
service territory.

As Roseville does not have any black start
facilities in the state of California, no loads
or facilities meet this criteria.
2 Distribution Facility that is the primary source of
electrical service to a military installation
essential to national security and/or emergency
response services (may include certain airfields,
command centers, weapons stations,
emergency supply depots)
Roseville reviewed customer and load
attributes to identify those specifically
critical to national security and/or
emergency response services.

Roseville potentially identified and included
1 primary source of electrical service.
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)
Roseville defines “regional drinking water
supplies and wastewater services” to mean
a facility providing the primary source of
these services to over 40,000 customer
accounts or to an area with a population of
over 100,000.

Based on the approach described above,
Roseville identified and included 2
Distribution Facilities with the potential to
impact a significant portion of the Roseville
community.
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)
Roseville defines “regional public safety
establishment” as any of the following: (1) a
major police or fire department serving 1.5
million population with an least 1000 sworn
officers; (2) County Sheriff’s Department
Headquarters; (3) County Emergency
Operations Center; (4) County/State Fire
Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
10 headquarters; (5) a California State Prison;
(5) a United States Penitentiary; or (6) a
Federal Correctional Institute.

Roseville identified 1 Distribution Facility that
met this requirement.
5 Distribution Facility that serves a major
transportation facility (may include International
Airport, Mega Seaport, other air traffic control
center, and international border crossing)
In addition to the facilities listed in the Joint
IOU/POU Straw Proposal, Roseville defines a
“major transportation facility” as any
transportation facility that has (1) an
average of 600 or more flights per day; or
(2) 50,000 passengers per day.

Roseville identified 1 Distribution Facility that
met this requirement.
6 Distribution Facility that serves as a Level 1
Trauma Center as designated by the Office of
Statewide Health Planning and Development
Roseville reviewed current listings of Level 1
Trauma Centers and cross referenced with
the company’s service territory and
customer information. No Level 1 Trauma
Centers are found to be located within
Roseville Electric Utility’s service territory.
7 Distribution Facility that serves over 60,000 meters Roseville identified a Distribution Facility providing electrical service to over 60,000
customers.

Note: The “Roseville’s Specific Approach” in the table above was defined by Electric Staff.

B. IDENTIFICATION ANALYSIS
In performing this identification analysis, Roseville 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 Roseville as the entity responsible for operation and maintenance. These specific types of facilities include Distribution Facilities.

Based on this scope, Roseville has identified fifteen Distribution Facilities that are subject to this identification analysis. Of the fifteen Distribution Substations, four fell within one of the covered categories listed above. The Covered Distribution Facility Category Matrix below summarizes this 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
Facility 1 X X
Facility 2 X
Facility 3 X
Facility 4 X
Covered Distribution Facility Category Matrix
Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
11 V. RISK ASSESSMENT (STEP 1B)
A. METHODOLOGY
Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, Roseville will assess 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; (3) discharge of a firearm; and (4) sabotage. A “successful physical attack” is limited to circumstances where a theft, vandalism, discharge of a firearm, and/or sabotage 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. While no sabotage related incident has occurred at the facilities in the past, Roseville continues to monitor for sabotage related threats.

In order to perform this risk analysis, Roseville evaluated 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 resiliency and other measures in place.

B. MITIGATION MEASURES
D.19-01-018 identifies the specific mitigation measures that a utility should consider when performing this risk analysis. The following table lists these mitigation measures and provides additional clarifications that are necessary to apply these measures to Roseville’s territory.

Measure D.19-01-018 Description Additional Clarification 1 The existing system resiliency and/or
redundancy solutions (e.g., switching the load
to another distribution substation or circuit
capable of serving the load, temporary circuit
ties, mobile generation and/or storage
solutions).

No additional clarification.
2 The availability of spare assets to restore a
particular load.

No additional clarification.
3 The existing physical security protections to
reasonably address the risk.

No additional clarification.
4 The potential for emergency responders to
identify and respond to an attack in a timely
manner.

Each facility is evaluated based on a law
enforcement officer arriving at the
Covered Distribution Facility within 15
minutes of a report from the public of a
break in or attack, or of Roseville notifying
the law enforcement agency of the
triggering of an alarm at the facility.
5 Location and physical surroundings, including
proximity to gas pipelines and geographical
challenges, and impacts of weather.

Roseville evaluated this element based on
the proximity of the Covered Distribution
Facility to populated areas and the extent
to which the interior of the facility is
Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
12 shielded from view due to walls,
vegetation, or other visual obstructions.
6 History of criminal activity at the Distribution
Facility and in the area.

Roseville evaluated the property crime
rates in the immediate vicinity of the
Covered Distribution Facility from Roseville
Police Department and compared those
crimes rates to property crime rates for the
county and the state to determine if the
area is subject to a higher than average
incidence of property related crimes.
7 The availability of other sources of energy to
serve the load (e.g., customer owned back-up
generation or storage solutions).

No additional clarification.
8 The availability of alternative ways to meet the
health, safety, or security.

No additional clarification.
9 Requirements served by the load (e.g., back up
command center or water storage facility).

No additional clarification.

Figure 1 below illustrates the causes of a successful physical security attack (Top Event) and Covered Distribution Facility consequences, as well as prevention measures to prevent a physical security attack and control measures that can be employed to mitigate the outcome.

Figure 1: Roseville Bow-Tie Assessment of Covered Distribution Facilities Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
13 C. RISK ASSESSMENT
Based on the process described in the Joint IOU/POU Straw Proposal and the direction provided in D.19-01-018, Roseville has determined that of the four Covered Distribution Facilities identified in Section IV, the existing programs and measures in effect at each Covered Distribution Facility effectively mitigate the risks of a physical attack.

All Covered Distribution Facilities are initially designated as high risk given the nature of the proceeding and the assessment of impact through the identification of critical loads. The assessed risk level of each Covered Distribution Facility is then a result of both the presence and the effectiveness of existing prevention and control mitigation measures in place. A greater number of more effective measures reduce the risk level at a greater rate than fewer or less effective measures.

The following section includes the results of applying this methodology to the four Covered Distribution Facilities along with the resulting assessment of each mitigation measure for each Covered Distribution Facility and the assessed risk level.

The following table provides the results of applying this methodology to the four Covered Distribution Facilities and a summary of Roseville’s assessment of each mitigation measure for each Covered Distribution Facility.

Mitigation Facility 1 Facility 2 Facility 3 Facility 4

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).

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

2. The availability of spare assets to restore a
particular load.

Partly
Effective
Partly
Effective
Partly
Effective
Partly
Effective

3. The existing physical security protections to
reasonably address the risk.

Partly
Effective
Partly
Effective
Fully
Effective
Partly
Effective

4. The potential for emergency responders to
identify and respond to an attack in a timely
manner.

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

5. Location and physical surroundings, including
proximity to gas pipelines and geographical
challenges, and impacts of weather.

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

6. History of criminal activity at the Distribution
Facility and in the area.

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

7. The availability of other sources of energy to
serve the load (e.g., customer owned backup generation or storage solutions).

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

8. The availability of alternative ways to meet
the health, safety, or security.

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective

9. Requirements served by the load (e.g., back
up command center or water storage
facility).

Fully
Effective
Fully
Effective
Fully
Effective
Fully
Effective
Roseville Electric Utility Security Plan
JulyNovember , 01, 20212022
14 As identified above, the four identified Covered Distribution Facilities have existing mitigating measures sufficient to effectively mitigate the identified risks of a physical attack. These facilities are discussed in Section VI.

VI. COVERED DISTRIBUTION FACILITY MITIGATION PLANS (STEP 1C) Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, Roseville has determined that for the four Covered Distribution Facilities that are subject to Roseville’s control, the existing and planned mitigation measures effectively reduce the risk of a physical security attack to a from medium to low/very low risk. This section describes the existing Mitigation Plan that Roseville utilizes for the four Covered Distribution Facilities.

In order to perform this risk analysis, Roseville evaluated the relative risk that (1) a physical attack on a Covered Distribution Facility would be successful considering the protective measures in place; or (2) that the impacts of a successful attack would be mitigated due to resiliency and other measures in place. Throughout the below analysis Roseville determined that the physical security risks for the identified Covered Distribution Facilities are low with Roseville’s existing resiliency, security measures, and planned mitigation efforts.

1. System resilience: The vast majority of Roseville’s system has been designed to handle the anticipated loss of service to a major component (transformer, 60kv line, 12kv feeder etc.). Once Roseville reaches the individual customer level, loss of a pad mount transformer or service drop would require the repair/replacement prior to having the power restored.

2. Spare assets: Roseville’s system has been designed to accommodate the loss of any one of the identified Covered Distribution Facilities (via switching on Roseville’s distribution system). Other components such as wire, cable, distribution switches, pad mount transformers, and wood pole replacements are readily available in stock, with the exception of metal switchgear.

Roseville performs detailed contingency analysis on the loss of a substation transformer biennially. This analysis is performed using distribution load flow software and takes into account updated load forecasts. Detailed switching schedules have been prepared for the loss of every substation transformer. While Roseville operates a radial distribution system, all circuits are looped (with normal open points) and mitigation of the loss of a transformer can be accommodated by using the excess capacity on other substation transformers and 12kV circuits.

3. Existing physical security protections: Includes door alarms, brick and wire fencing, exterior lighting, barbed wire, and perimeter beams. Note that door alarms, perimeter beams, and exterior gate contacts are monitored through the Roseville SCADA system.

4. Emergency responders to respond to occurrence: The Covered Distribution Facilities were not built with the express purpose of emergency responder access however, all are Roseville Electric Utility Security Plan
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15 within the City limits, and most are adjacent to roadways and have reasonable access for the Roseville Police Department and Roseville Fire Department emergency response crews. Important to note that City of Roseville is a full service city with its own fire and police departments.

5. Location and physical surroundings, including proximity to gas pipelines and geographical challenges, and impacts of weather: The above mentioned Covered Distribution Facilities are located in an urban area and all are within the City of Roseville limits. No major gas transportation pipelines are close to the Covered Distribution Facilities.

6. History of criminal activity at the Covered Distribution Facilities and in the area: Graffiti happens infrequently (not typical) and addressed during monthly routine inspections as needed (if graffiti is detected it is addressed within two days). Roseville has had one theft at Facility 2 (loss of a portable propane tank) in 2018.

7. The availability of other sources of energy to serve the load (e.g., customer owned backup generation or storage solutions): Roseville has evaluated the potential for customer owned generation at each critical load as a part of this assessment. All identified critical load entities maintain backup generation in the event that a successful physical attack occurs on the Covered Distribution Facilities and in the highly unlikely event that secondary sources are not available. The backups are tested on a yearly basis to ensure they are working if they are called upon. City owned critical facilities are evaluated on an annual basis to ensure backup generation is reliable and available.

8. The availability of alternative ways to meet the health, safety, or security: Roseville’s existing resilience, backup generation, and availability of secondary sources to feed the load provide multiple options to meet health, safety, and security. At this time, Roseville is not formally considering providing alternate ways to meet the needs served by the critical loads as these needs are fully covered currently.

9. Requirements served by the load: The critical loads have backup generation available and are able to be fed by secondary sources. As a result it was determined that the load requirements would be met through alternative means as discussed in this section.

A. COVERED DISTRIBUTION FACILITY MITIGATION PLAN
Roseville operates the electric grid with the lowest level of risk reasonably attainable. After an extensive review of Roseville’s existing methodology, it was determined that the risk level for the four Covered Distribution Facilities was slightly below medium. The This Facility Mitigation Plan will increase the physical security measures by December 31, 2022. Roseville will also develop a utility-wide physical security plan that will create a more holistic approach to Facility security.

Roseville takes an active approach to both physical security and system resilience, thus proactively reducing potential risks, as shown in Figure 2 & 3 below.

Roseville Electric Utility Security Plan
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16 The previous version of the plan indicated that Roseville would take measures to increase security by December 31, 2022. Roseville has identified several measures as best practice for covered facilities. Roseville will begin a multi-year process to incorporate these improvements to new and existing substations as practical.

Figure 2: Roseville Risk Methodology Baseline Prior to Assessment The heat map above indicates the baseline risk prior to existing physical and resilience measures that Roseville has in place or is in the active process of implementing based on the analysis performed during the assessment.

Roseville Electric Utility Security Plan
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17 Figure 3: Roseville Risk Methodology Post Mitigation Measures The post mitigation heat map above illustrates Roseville’s four Covered Distribution Facilities risk exposure moving to the low/very low quadrant due to existing and planned physical and resilience measures. Roseville will continue to identify and assess potential risks associated with Covered Distribution Facilities and apply the methodologies described in this document consistent with D.19-01-018.

Roseville also considered the emerging threats below that after current evaluation considered them to be low risk:
 Insider threats: Roseville has a documented process that includes performing Personal Risk Assessments (PRA) during the hiring process to identify any potential past issues with the perspective employee being considered for employment. Roseville also has a documented process to remove the employee's physical and network access when they are no longer employed by Roseville.
 Unmanned aerial vehicles (UAVs): Roseville monitors and evaluates these emerging industry trends. UAV activity near the Covered Distribution Facilities was determined to be very low at this time.
 Supply chain risk: Should the Roseville supply chain become unavailable, Roseville would address this through spare assets on hand or request needed materials through the use of existing mutual aid agreements with neighboring utilities.

VII. INDEPENDENT EVALUATION AND RESPONSE (STEP 2)
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18 A. REQUIREMENTS FOR QUALIFIED THIRD PARTY REVIEW
D.19-01-018 specifies the following criteria for a Qualified Third Party:

Independence: A Qualified Third Party 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, so 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 thirdparty reviewer if it has the appropriate expertise.

Adequate Qualifications: A Qualified Third Party must be an entity or organization with electric industry physical security experience and whose review staff has appropriate physical security expertise, which means that it meets one of the following: (1) an entity with at least one member who holds either an ASIS International Certified 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 security assessments by the CPUC, Electric Reliability Organization, or similar electrical industry regulatory body.

B. IDENTIFICATION OF THIRD PARTY REVIEWER
Roseville has will selected as its Third Party Reviewer AESI-US, Inc. (AESI)for the 5-year review or as needed. AESI is an independent third party and not a part of the City of Roseville. AESI meetsThe reviewer will meet the second qualification criterion above, “an entity or organization with demonstrated law enforcement, government, or military physical security expertise.” C. PUBLIC RESULTS OF THIRD PARTY EVALUATION
AESI has reviewed the Roseville’s Physical Security Plan pursuant to the California Public Utilities Commission’s (“CPUC”) Phase 1 Decision on Order Instituting Rulemaking Regarding the Physical Security of Electrical Corporations, dated January 10, 2019, which requires electric utilities to identify electric distribution assets that may merit special protection and measures to lessen identified risks and threats.

AESI made several recommendations to improve current physical security measures. The recommended changes are not a requirement but best industry practices.

D. ROSEVILLE ELECTRIC UTILITY RESPONSE
Roseville will implement develop a plan to install security cameras as the recommended physical security enhancements at the identified Covered Distribution Facilities by December 31, 2022. Currently Roseville has separate physical security plans for different sections of the organization. Roseville will work towards completing a holistic department wide physical security plan that would combine existing measures.

Roseville Electric Utility Security Plan
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19 VIII. VALIDATION (STEP 3)
A. SELECTION OF QUALIFIED AUTHORITY
Roseville selected the Roseville Police Department as its Qualified Authority to conduct the validation step of the physical security as required. Roseville’s Police Department is a separate department from the utility, therefore they are independent in their validation review. Employees from the Roseville Police Department have been through extensive training focusing on physical security of electric substations in the last five years. Roseville feels that the Roseville Police Department is the perfect entity to validate Roseville’s Physical Security Plan and measures. and may continue to use the Roseville Police Department in the future.

B. RESULTS OF QUALIFIED AUTHORITY REVIEW
The Roseville Police Department reviewed and determined that current measures are adequate based on the mitigation plan and the fact that local crimes are not targeting the Covered Distribution Facilities.

C. ROSEVILLE ELECTRIC UTILITY RESPONSE TO QUALIFIED AUTHORITY REVIEW
Roseville continues to work with the Roseville Police Department to improve and enhance physical security measures.

IX. NARRATIVE DESCRIPTIONS FOR UTILITY SECURITY PLAN
A. ASSET MANAGEMENT PROGRAM
Roseville utilizes a Computer Maintenance Management System (CMMS) for asset and inventory management. This software is an enterprise asset management solution (equipment, installations, buildings, etc.) and includes services such as purchasing, inventory, location management, service desk, and work planning.

This CMMS software tracks the majority of items in Roseville’s warehouses. The software is used to:
 track when inventory falls below “safety-stock” reorder points  perform cycle counts and make appropriate adjustments  create purchase requisitions and purchase orders to restock needed items  capture transactions such as receipts, issues, transfers and returns The utilization of an inventory management program optimizes service levels by tracking each item’s location, number in stock and how many are available. CMMS manages Roseville’s field assets as well. Roseville uses time based scheduling for maintenance planning and inspections. Workforce mapping and asset visualization is accomplished through the CMMS’s Roseville Electric Utility Security Plan
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20 geospatial connection to Roseville’s Geographic Information System (GIS). Work orders are created and closed in the field on mobile devices which help to streamline the process.

B. WORKFORCE TRAINING AND RETENTION
Roseville staff are highly trained in all aspects of infrastructure operations at all four Covered Distribution Facilities. Personnel are available via call back in the event of an emergency and/or to initiate repairs utilizing Roseville’s spare part inventory. Finally, Roseville is aware that retention of employees with these skill sets are a necessity and continues to work on maintaining a positive work environment.

C. PREVENTATIVE MAINTENANCE PLAN
Roseville has a Standard Operating Procedure as a documented preventative maintenance plan for identified equipment (PRC-005-6 or its successor version) to ensure that mitigation measures are functional and performing adequately. It establishes procedures for analyzing, mitigating, and providing documentation regarding failures and corrective action plans internally. It also establishes standard procedures for reporting protection system failures and misoperation.

Roseville performs preventative maintenance on a scheduled basis on all distribution facility assets, such as: breakers, switch gear, substation transformers, and physical security systems.

Roseville utilizes a maintenance program for substation inspections. The objective of this program is to establish a standard for utility operations use pertaining to type, frequency and grading of the City’s electric utility substation activities.

Additionally, the Covered Distribution Facilities use a Computer Maintenance Management System (CMMS) to track and schedule maintenance activities. CMMS is a software package that maintains a computer database of information about Roseville’s maintenance operations.

D. PHYSICAL SECURITY EVENT TRAINING
The City of Roseville has an Emergency Management Team (EMT) that meets regularly and has representatives from each City department as part of the team. The EMT works to ensure that the City of Roseville is prepared to respond to disasters that may occur within the City. The City Manager acts as the Emergency Services Director. The Director works closely with city staff during a disaster; while the day-to-day operation of disaster preparedness and readiness lies with the Emergency Preparedness Manager, a Roseville Fire Department Battalion Chief.

The City of Roseville is a member of the California Utility Emergency Association (CUEA), which plays a key role in ensuring communications between utilities during emergencies. CUEA serves as a point-of-contact for critical infrastructure utilities, CalOES and other governmental agencies before, during and after an event.

Roseville has worked with local law enforcement on the four Covered Distribution Facilities to educate them on physical hazards, points of entry and protection. Roseville and local law Roseville Electric Utility Security Plan
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21 enforcement participate semiannually with the City’s EMT on Emergency Operations Center scenarios, further increasing communication between agencies. Roseville also belongs to the Electricity Information Sharing and Analysis Center (E-ISAC) which is a trusted source of quality analysis and rapid sharing of security information for the electric industry.

ROSEVILLE ELECTRIC UTILITY

PHYSICAL SECURITY PLAN
PUBLIC REPORT ON ROSEVILLE ELECTRIC UTILITY’S
PHYSICAL SECURITY PROGRAM FOR DISTRIBUTIONLEVEL FACILITIES December 7, 2022

TABLE OF CONTENTS
I. Overview ................................................................................................................................................. 4 A. Goal of Utility Security Plan .............................................................................................................. 4 B. Description of Roseville Electric Utility ............................................................................................ 4 C. Results of Utility Security Plan Assessement.................................................................................... 4 II. Background ............................................................................................................................................ 5 III. Plan Development Process.............................................................................................................. 6 A. Physical Security Principles............................................................................................................... 6 B. Utility Security Plan Development Process..................................................................................... 7 STEP 1: Assessment/Plan Development .............................................................................................. 7 STEP 1A: Identify Covered Distribution Facilities ................................................................................ 7 STEP 1B: Perform Risk Assessment......................................................................................................... 7 STEP 1C: Develop Mitigation Plan........................................................................................................ 7 STEP 2: Independent Review ................................................................................................................ 8 STEP 3: Validation ................................................................................................................................... 8 STEP 4: Adoption..................................................................................................................................... 8 STEP 5: Maintenance ............................................................................................................................. 8 STEP 6: Repeat Process.......................................................................................................................... 8 IV. Identification of Covered Distribution Facility (Step 1A)............................................................. 9 A. Identification Factors........................................................................................................................ 9 B. Identification Analysis..................................................................................................................... 10 V. Risk Assessment (Step 1B).................................................................................................................... 11 A. Methodology ................................................................................................................................... 11 B. Mitigation Measures........................................................................................................................ 11 C. Risk Assessment................................................................................................................................ 13 VI. Covered Distribution Facility Mitigation Plans (Step 1C)........................................................... 14 A. Covered Distribution Facility Mitigation Plan .............................................................................. 15 VII. Independent Evaluation and Response (Step 2)....................................................................... 17 A. Requirements for Qualified Third Party Review........................................................................... 18 B. Identification of Third Party Reviewer........................................................................................... 18 C. Public Results of Third Party Evaluation ........................................................................................ 18 D. Roseville Electric Utility Response.................................................................................................. 18 VIII. Validation (Step 3) .......................................................................................................................... 19 A. Selection of Qualified Authority .................................................................................................... 19 B. Results of Qualified Authority Review........................................................................................... 19 C. Roseville Electric Utility Response to Qualified Authority Review............................................. 19 IX. Narrative Descriptions for Utility Security Plan............................................................................. 19 A. Asset Management Program........................................................................................................ 19 B. Workforce Training and Retention................................................................................................ 20 C. Preventative Maintenance Plan................................................................................................... 20 D. Physical Security Event Training..................................................................................................... 20 Roseville Electric Utility Security Plan
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4 I. OVERVIEW
A. GOAL OF UTILITY SECURITY PLAN
Ensuring the safety of its facilities is a top priority for Roseville Electric Utility (Roseville). Roseville prioritizes safety in all aspects of its design, operation, and maintenance practices. The overarching goal of this Utility Security Plan is to describe Roseville’s risk management approach concerning “Covered Distribution Facilities” physical security as defined by the Joint IOU/POU Straw Proposal and D.19-01-018. Appropriate consideration of resiliency, impact, and cost factors were also considered.

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5 II. 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.

SED filed a response2 to the Joint IOU/POU Straw Proposal that recommended various modifications and clarifications, including a six step process. Additionally, SED recommended that the utility mitigation plans include: (1) an assessment of supply chain vulnerabilities; (2) training programs for law enforcement and utility staff to improve communication during physical security events; and (3) an assessment of any near-by communication utility infrastructure that supports a distribution substation. 1 Straw Proposal available at:
https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/R1506009- Updated%20Joint%20Straw%20Proposal%20and%20Cover%20083117%20Filing.pdf. 2 SED Response available at:
https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/Safety/Risk_Assessment/physicalsecurity/Final%20Staff %20Recommendation%20for%20Commission%20Consideration%20010318.pdf.

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6 In early 2019, the CPUC approved Decision (D.) 19-01-018, which adopted the Joint IOU/POU Straw Proposal as modified by the SED proposal, with additional clarifications and guidance.

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.

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 Substations, but only those that risk dictates would require additional measures.

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. 3 D.19-01-018 at 43, 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.”).

Roseville Electric Utility Security Plan
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7 B. UTILITY SECURITY PLAN DEVELOPMENT PROCESS
Roseville utilized a multi-step process to develop this Utility Security Plan that is consistent with the Joint IOU/POU Straw Proposal and D.19-01-018. The intent of the proposal is to implement a risk management approach toward distribution system physical security, with appropriate consideration of resiliency, impact, and cost. In order to accomplish this risk-based approach, general principles were derived from information described and evaluated during meetings to guide the utility’s overall evaluation of Distribution Facilities. The relevant six steps of that process are the following:

STEP 1: ASSESSMENT/PLAN DEVELOPMENT
Roseville’s staff prepared a Draft Utility Security Plan through the process set forth in Steps 1A, 1B, and 1C. Please note the following principles:
• Distribution Facilities 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 of a significant attack.
• Distribution Facilities 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.
• The focus of this assessment is both physical security protection and operational resiliency on the identified critical load facilities (Covered Distribution Facilities) in which additional risk mitigation measures are required.

STEP 1C: DEVELOP MITIGATION PLAN
If there are 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 Roseville will develop a Mitigation Plan for that Roseville Electric Utility Security Plan
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8 Covered Distribution Facilities. The Mitigation Plan will use a risk-based approach to select reasonable and cost-effective measures that can either be security focused (e.g., walls or alarms) or resiliency focused (e.g., adequate spare parts).

STEP 2: INDEPENDENT REVIEW
Roseville’s Utility Security Plan cycle will contain the identification process, risk assessment, and Mitigation Plan development performed pursuant to Steps 1A, 1B, and 1C. This documentation in combination with the narrative description in Sections IV-VI below will constitute Roseville Electric Utility’s Draft Utility Security Plan. Each Draft Utility Security Plan is submitted to a Qualified Third Party for Independent Review. The Qualified Third Party may then issue an evaluation that identifies any potential deficiencies in the Draft Utility Security Plan as well as recommendations for improvements. Roseville will then modify its plan to address any identified deficiencies or recommendations. The combination of the Draft Utility Security Plan, the nonconfidential conclusions of the Qualified Third Party, and Roseville’s responses to the Qualified Third Party Review will constitute Roseville Electric Utility’s Utility Security Plan.

STEP 3: VALIDATION
Roseville may submit its Utility Security Plan to a qualified authority for review. Such entity will provide additional feedback and evaluation of Roseville Electric Utility’s Utility Security Plan and, to the extent that this entity is authorized, such entity deems the Utility Security Plan as adequate.

STEP 4: ADOPTION
Roseville’s Utility Security Plan will be presented to and adopted by City of Roseville’s Council at a public meeting.

STEP 5: MAINTENANCE
Roseville will refine and update the Utility Security on an ongoing basis as appropriate and necessary to preserve plan integrity.

STEP 6: REPEAT PROCESS
Roseville will repeat this six step process at least once every five years or sooner if circumstances dictate.

Roseville Electric Utility Security Plan
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9 IV. IDENTIFICATION OF COVERED DISTRIBUTION FACILITY (STEP 1A) As described in Section III, Step 1A of the Utility Security Plan process involves assessing all distribution-level facilities that are subject to the control of Roseville to determine which facilities are “Covered Distribution Facilities” subject to the need for a risk assessment. This Section describes the factors that Roseville used to evaluate its distribution facilities and the results of its evaluation.

Based on the approach described above,
Roseville identified and included 2
Distribution Facilities with the potential to
impact a significant portion of the Roseville
community.
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)
Roseville defines “regional public safety
establishment” as any of the following: (1) a
major police or fire department serving 1.5
million population with an least 1000 sworn
officers; (2) County Sheriff’s Department
Headquarters; (3) County Emergency
Operations Center; (4) County/State Fire
Roseville Electric Utility Security Plan
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10 headquarters; (5) a California State Prison;
(5) a United States Penitentiary; or (6) a
Federal Correctional Institute.

Note: The “Roseville’s Specific Approach” in the table above was defined by Electric Staff.

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
Facility 1 X X
Facility 2 X
Facility 3 X
Facility 4 X
Covered Distribution Facility Category Matrix
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11 V. RISK ASSESSMENT (STEP 1B)
A. METHODOLOGY
Pursuant to the process identified in the Joint IOU/POU Straw Proposal and D.19-01-018, Roseville will assess 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; (3) discharge of a firearm; and (4) sabotage. A “successful physical attack” is limited to circumstances where a theft, vandalism, discharge of a firearm, and/or sabotage 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. While no sabotage related incident has occurred at the facilities in the past, Roseville continues to monitor for sabotage related threats.

No additional clarification.
2 The availability of spare assets to restore a
particular load.

No additional clarification.
3 The existing physical security protections to
reasonably address the risk.

No additional clarification.
4 The potential for emergency responders to
identify and respond to an attack in a timely
manner.

Roseville evaluated this element based on
the proximity of the Covered Distribution
Facility to populated areas and the extent
to which the interior of the facility is
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12 shielded from view due to walls,
vegetation, or other visual obstructions.
6 History of criminal activity at the Distribution
Facility and in the area.

No additional clarification.
8 The availability of alternative ways to meet the
health, safety, or security.

No additional clarification.
9 Requirements served by the load (e.g., back up
command center or water storage facility).

No additional clarification.

Figure 1: Roseville Bow-Tie Assessment of Covered Distribution Facilities Roseville Electric Utility Security Plan
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13 C. RISK ASSESSMENT
Based on the process described in the Joint IOU/POU Straw Proposal and the direction provided in D.19-01-018, Roseville has determined that of the four Covered Distribution Facilities identified in Section IV, the existing programs and measures in effect at each Covered Distribution Facility effectively mitigate the risks of a physical attack.