Details for: SCE's Reply to Protests to Advice 3786-E Data Redaction.pdf


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Gary Stern, Ph.D.
Managing Director, State Regulatory Operations

May 14, 2018
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re:

Reply to the Protests of the Interstate Renewable
Energy Council, Solar Energy Industries Association,
Clean Coalition, The Office of Ratepayer Advocates,
and Sunrun, Inc., Regarding Advice Letter 3786-E

Dear Energy Division Tariff Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission’s or CPUC’s) General Order 96-B, Southern California Edison Company
(SCE) hereby submits this reply to the protests (Protests) of the Interstate Renewable
Energy Council (IREC), Solar Energy Industries Association (SEIA), Clean Coalition, the
Office of Ratepayer Advocates (ORA) and Sunrun, Inc. regarding SCE Advice 3786-E,
Southern California Edison Company’s Distribution Resources Plan Data Redaction
Criteria in Compliance with Decision 18-02-004.
I.

Background

On April 16, 2018, SCE filed Advice 3786-E to seek approval of its Distribution
Resources Plan (DRP) Data Redaction Criteria in compliance with Ordering Paragraph
(OP) 2g of Decision (D.)18-02-004 (Decision).
On May 7, 2018, IREC, SEIA, Clean Coalition, ORA and Sunrun filed protests to Advice
3786-E.1

1

IREC’s Protest to Pacific Gas and Electric Company’s Advice Letter 5276-E, San Diego Gas
and Electric Company’s Advice Letter 3210-E, and Southern California Edison Company’s
Advice Letter 3786-E – Data Redaction Criteria in Response to the Decision on the
Distribution Investment and Deferral Process (D.18-02-004 (“IREC Protest”); Protest of the
Solar Energy Industries Association to Pacific Gas and Electric Company Advice 5276-8,
San Diego Gas & Electric Company Advice 3210-E, and Southern California Edison
Company Advice 3786-E: Data Redaction Criteria in Response to the Decision on the
Distribution Investment and Deferral Process lD-l8-02-004] (“SEIA Protest”); Protest of San
Diego Gas and Electric Company’s Advice Letter 3210-E, Pacific Gas and Electric
Company’s Advice Letter 5276-E, and Southern California Edison Company’s Advice Letter

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

FAX (626) 302-6396





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Energy Division Tariff Unit Page 2 May 14, 2018 SCE hereby replies to the Protests received May 7, 2018. II. Reply to Protests A. Redaction is Necessary and Does Not Undermine DRP Goals SCE takes its role in protecting release of information that could pose a threat to physical security or cybersecurity seriously. Consistent with the Decision, the data redaction criteria proposed in SCE’s Advice 3786-E are meant to “ensure the physical and cyber security of the electric system.”2 They are intended to serve as preventative measures that help minimize the risk to the electric grid from bad actors. Some Protests questioned whether there is sufficient support for SCE’s proposed redactions.3 SCE believes the basis it provided clearly supports the redaction of three categories of information related to physical security identified in its Advice 3786-E: “Facility ID,” “Existing facility/equipment rating,” and “Forecasted percentage deficiency above the existing facility/equipment rating.”4 Disclosure of these three categories can provide a roadmap for those with hostile intentions to identify and attack exploitable locations. First, SCE proposed redacting the “Facility ID” to prevent bad actors from easily identifying the exact equipment requiring upgrades or alternatives solutions as well as the precise location of this equipment. Second, SCE proposed redacting “Existing facility/equipment rating” to prevent a bad actor from easily locating vulnerable elements of the system, such as equipment serving large amounts of load and equipment with limited transfer capabilities. Importantly, different from other IOUs, SCE’s sub-transmission system is to be included in the scope of its Grid Needs Assessment Report (GNA) and Distribution Deferral Opportunity Report (DDOR). Sub-transmission systems affect a much larger population of customers and disclosing sensitive information such as equipment ratings will impose a much higher risk to the grid safety. 2 3 4 3786-E – Data Redaction Criteria in Response to the Decision D.18-02-004 on the Distribution Investment and Deferral Process (“Clean Coalition Protest”); Protest of the Office of Ratepayer Advocates to Pacific Gas and Electric Advice Letter 5276-E, Southern California Edison Advice Letter 3786-E, and San Diego Gas & Electric Advice Letter 3210E,Distribution Resources Plan Data Redaction Criteria Responses to the Decision on the Distribution Investment and Deferral Process (D.18-02-004) (“ORA Protest”); Sunrun, Inc.’s Joint Protest to Pacific Gas & Electric’s Advice Letter 5276-E, Southern California Edison’s Advice Letter 3786-E, and San Diego Gas & Electric’s Advice Letter 3210-E (“Sunrun Protest”). Decision 18-02-004, p. 4 and Ordering Paragraph No. 2g, p. 84. See e.g., ORA Protest, at p. 5; SEIA Protest, at pp. 5-6. SCE notes that no party protested its proposed data redaction to protect customer privacy protection. Accordingly, it does not provide further discussion on this issue in these reply comments.
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Energy Division Tariff Unit Page 3 May 14, 2018 Third, SCE proposed redacting “Forecasted percentage deficiency above the existing facility/equipment rating,” instead only displaying the “Forecasted deficiency above the existing facility/equipment rating (MW, kVA, or other).” Providing the forecasted deficiency above the existing facility/equipment rating (MW, kVA, or other) in the GNA and DDOR reports will allow stakeholders to be able to fully understand the magnitude of the desired grid needs while ensuring the security of the grid.5 Redacting the forecasted percentage above the existing facility/equipment rating will prevent a bad actor from determining the underlying equipment rating. Clean Coalition asserts that “the location of the electric grid is inherently not secret – it exists in public space for all to see” and further asserts that such redactions do not offer “protection from a potential dedicated bad actor.”6 However, disclosing additional information such as the equipment rating or the identification information of the equipment as part of a projection of grid needs in a GNA or DDOR can provide those with hostile intentions a readily-available list of vulnerabilities and weaknesses on the system, which they can easily use to identify and attack exploitable locations. SCE notes that it carefully evaluated the balance between security and transparency, to ensure continued support of the DRP goals of achieving greater integration of DERs in a manner consistent with maximizing ratepayer benefits; the proposed data redaction criteria do not undermine these goals. SCE’s proposed redactions will not inhibit thirdparties from understanding distribution grid needs, their drivers, and the cost of utility expenditures otherwise required to meet these needs. As Clean Coalition acknowledges, “identification of specific facilities and the rating of these facilities or percentage forecast deficiency may not be needed by respondents and may (be) [sic] redacted without undue harm, and might theoretically offer information that could be present some exploitable vulnerability risk.”7 IREC asserts that the proposed redacted information is necessary to allow DER developers to “begin customer engagement activities in areas with distribution needs.”8 This is not correct, as SCE is proposing to still include the location of the distribution needs combined with the total deficiency over the five year forecast horizon. These two combined pieces of data will provide DER developers with sufficient information to understand where DERs must be installed and the attributes required to realize a 5 6 7 8 Sunrun’s Protest attached a “Locational Grid Services Paper,” which presents a list of information it asserts a DER developer needs, and this list includes the equipment rating. However, the paper fails to explain why this information is needed beyond a general statement that “[u]nderstanding the sizing (or capacity) of individual network elements such as feeders and transformers allows an assessment to be made of spare headroom when compared with network demand data.” Sunrun Protest, at Attachment p. 6. The actual forecasted deficiency above existing facility rating, along with the need profiles to be provided in the LNBA implementation which shows the hourly gird needs, can provide the essential information DER developers need to develop solutions. Clean Coalition Protest, page 3. Clean Coalition, at p. 2. IREC, at p. 6.
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Energy Division Tariff Unit Page 4 May 14, 2018 deferral. In addition, it may be unlikely that DER developers would begin expending resources on customer engagement before a project is considered deferrable and identified for solicitation, due to expending cost without clear direction on future solicitation activities. When a project is selected as a deferrable project in the Distribution Planning Advisory Group (DPAG) review process, detailed project information, including the location and the needs, will be provided in the RFO process. Third-party stakeholders who are interested in participating will still be able to obtain all the information needed to develop a cost-effective and competitive solution. Finally, SCE notes that SEIA and Sunrun misinterpret SCE’s proposal and incorrectly conclude that SCE proposes to redact all the Substation and Circuit IDs, in addition to Facility IDs.9 This is not SCE’s proposal. Instead, SCE proposes to redact only the Facility ID from the GNA/DDOR requirement of “Substation, Circuit, and/or Facility ID” to keep the information release at the circuit level and to avoid the unnecessary level of specificity to the Facility ID. III. Conclusion SCE thanks the Commission for the opportunity to provide these reply comments to the protests of Advice 3786-E. Sincerely, /s/ Gary A. Stern, Ph. D. Gary A. Stern, Ph. D. GAS:ag:jm cc: 9 Edward Randolph, Director, CPUC Energy Division Sky C. Stanfield, IREC Jeanne B. Armstrong, SEIA Kenneth Sahm White, Clean Coalition Chloe Lukins, ORA Tim Lindl, Sunrun, Inc. Service List R.14-08-013 SEIA, at p. 3; Sunrun, at p. 6.
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