Details for: SDGE Protest Reply - AL 3210-E.pdf


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Clay Faber - Director
CA & Federal Regulatory
8330 Century Park Ct
San Diego, CA 92123
cfaber@semprautilities.com

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

Reply of San Diego Gas & Electric to Protests of SDG&E Advice Letter 3210-E: San
Diego Gas & Electric Submission of Proposed Distribution Resource Planning Data
Redaction Criteria Pursuant to Decision 18-02-004

In accordance with Section 7.4.3 of General Order 96-B, San Diego Gas & Electric Company
(“SDG&E”) hereby replies to the Protests filed by the Office of Ratepayer Advocates (“ORA”), the
Interstate Renewable Energy Council (“IREC”), the Solar Energy Industries Association (“SEIA”),
SunRun Inc. (“SunRun”), the California Energy Storage Alliance (“CESA”) and Clean Coalition to
SDG&E Advice Letter (“AL”) 3210-E, San Diego Gas & Electric Submission of Proposed
Distribution Resource Planning Data Redaction Criteria Pursuant to Decision 18-02-004, filed on
April 16, 2018.
Background
Pursuant to California Public Utilities Commission (“Commission”) Decision 18-02-004 (“D.”),
Ordering Paragraph (“OP”) 2.g and as a means to ensure continued physical and cyber security
of SDG&E’s electric system, SDG&E submitted AL 3210-E requesting that six data types and/or
attributes required to be made available by D.17-09-006 or D.18-02-004 should either be
removed, classified as confidential or substituted in a manner that does not diminish the value of
the Distributed Resource Planning (“DRP”) deliverables, while ensuring the physical and cyber
security of the electric system.
Within AL 3210-E, SDG&E informed the Commission of the time sensitive nature of that Advice
Letter, i.e., that some of the data SDG&E is requesting to be removed, classified as confidential
or replaced with equivalent but non-security compromising data, is per D.17-09-026 to be made
available by July 6, 2018. SDG&E requested approval of AL 3210-E by June 15, 2018 to enable
SDG&E sufficient time to comply with the Integrated Capacity Analysis (ICA) data mapping
requirements per D.17-09-026, while also ensuring that compliance does not expose SDG&E’s
system to physical or cyber security concerns.





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Public Utilities Commission May 14, 2018 On May 7, 2018, CESA, Clean Coalition, IREC, ORA, Sunrun, and SEIA filed protests to SDG&E’s AL 3210-E,1 requesting the Commission address, in part, the following issues:  Physical and cyber security and customer privacy are important issues, and should not be determined unilaterally by SDG&E. All six protesting parties acknowledge that ensuring physical and cyber security and customer privacy are important issues; however, each protesting party also recommends that the Commission reject SDG&E’s proposed redaction criteria because, in part, SDG&E has not provided actual examples of consequences of security breaches associated with providing the data requested to be redacted or replaced with less risky data.  Data redaction criteria should be consistent among SDG&E, SCE, and PG&E (“the IOUs”): Clean Coalition, CESA, and SEIA identify that the proposed redaction criteria differ between the three IOUs, and recommend that the Commission modify the proposals in a manner to allows consistency. Reply to Protests Broad Agreement that a Data Redaction Criteria is Needed to Address Customer Privacy and Physical/Cyber Security Risks: All of the parties protesting AL 3210-E appear to agree that data redaction criteria are needed to protect customer privacy and address grid security risks. This recognition is foundational to the redactions proposed in AL 3210-E. Additional Time May Facilitate Agreement on the Appropriate Data Redaction Criteria: The protesting parties appear to agree that some redaction is appropriate, and all six protesting parties support pursing interim solutions and/or appropriate modifications to the utility’s proposals. SDG&E supports that recommendation. However, given that the pending release of certain data is required by July 6, 2018, and the inability to recover the data and reverse the risks after its release, SDG&E supports an interim solution being the adoption of AL 3210-E, as proposed, and the scheduling of a workshop to allow additional discussion on this topic. Importantly, SDG&E’s proposed redactions, even if implemented on an interim basis, would modify only two aspects of the July 6, 2018, deployment. The other four data redactions are relevant to the 2019 deliverables and to the full deployment of the Grid Needs Assessment / Distribution Deferral Opportunity Report (GNA/DDOR) and portal. A postponement would be a viable alternative, since the anticipated need for many of the use-cases and deliverables are several months in the future. 1 The protests filed by Clean Coalition, IREC, ORA, Sunrun, and SEIA address SDG&E’s AL 3210-E as well as SCE’s AL 3786-E and PG&E’s AL 5276-E. 2
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Public Utilities Commission May 14, 2018 ICA Maps are not Simply Digitalizing Already Visually-Available Data: Clean Coalition asserts that “… the electric grid is inherently not secret …”, and therefore redacting information will not offer the protection SDG&E is requesting. Clean Coalition’s assertion is premised on its belief that the electric grid “exists in public space for all to see.” Clean Coalition’s belief is misguided. The majority of critical connections, key facilities, and underground assets are not visible to the public, and virtually none are known to the public as to their criticality (e.g. connectivity, loading) for grid reliability and the safety of employees and communities. Lack of Historical Events Does Not Equate to Lack of Potential to Occur: The protesting parties are in essence requesting the Commission require SDG&E to give evidence from an event that has not yet occurred (i.e. provide evidence that security impacts would have occurred if certain data had been made available to the public). SDG&E, on the other hand, requests that the Commission be a proactive safety manager and not wait for more evidence, at which time the damage would have already occurred. SDG&E reminds all parties what is not acceptable -- the release of data which could result in or exacerbate a destructive act. Such an act would be proof of SDG&E’s concerns, but the costs of such proof would obviously be unacceptable. With the exception of Clean Coalition, none of the protesters address the specific security risks addressed in AL 3210-E. SDG&E notes that the security risks discussed in AL 3210E represent just a few examples. There are many more, but SDG&E urges the Commission to be guarded in how it requests and assesses more detailed discussion of scenarios. The Commission’s adopted data redaction criteria should reflect a rolling-up of identified concerns and not a lowest common denominator philosophy: SDG&E agrees with the protests that characterize SDG&E’s proposed redaction criteria as being more extensive than in SCE’s and PG&E’s respective proposals, and as such, SDG&E considers its proposal to be the more complete of the three proposals and the more applicable base-line. SDG&E and SCE are both concerned that making facility IDs public will produce an exploitable vulnerability that will jeopardize security, and accordingly, SDG&E and SCE both propose to redact facility IDs. SCE notes that facility IDs could, “with little effort,” be used “in conjunction with other available data” to “identify and attack exploitable circuits, locations or customers.” SDG&E believes that other key data referenced by SCE should also be redacted, such as the circuit/conductor routing information that shows location and connectivity details. Hosting capacity, which will be provided, was always the need and intent of reflecting results of the ICA, and it is inappropriate to publicly share other details that further clarify and expose vulnerabilities. Additionally, SDG&E and SCE both propose to redact equipment ratings and forecast percentage deficiency. 3
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Public Utilities Commission May 14, 2018 SDG&E also recommends that the use of application programming interfaces (API) be limited to prevent rapid access to massive quantities of sensitive data. PG&E’s advice letter proposes to apply redaction criteria on a case-by-case basis to protect specific grid information. SDG&E believes that a case-by-case approach will allow the public release of large amounts of data which, after a specific case review, might subsequently be found to be sensitive. Redacting such sensitive information after it has been publicly released is ineffective and unacceptable. Rather than accept CESA’s recommendation to modify SDG&E’s proposal to align with SCE’s proposal, SDG&E believes a more appropriate recommendation is to modify PG&E’s and SCE‘s redaction criteria to align with SDG&E’s proposed criteria. DER Developers Can Use Color-Coordinated Grid/Parcel Mapping and a Combined Locational Net Benefits Analysis (LNBA)/Distribution Deferral Opportunities Report (DDOR) Mapping Layer to Optimally Locate DERs: Several protesters argue that SDG&E’s proposed data redactions will limit their commercial opportunities. SDG&E does not find merit in these arguments. Several of the DRP processes established by the Commission were intended to better facilitate opportunities for DER providers to cost-effectively defer distribution capacity needs. These opportunities will be sufficiently itemized in the DDOR and geographically shown on the combined LNBA/DDOR mapping layer. In addition, hosting capacity will be available in locational form on ICA maps. SDG&E does not believe other unrelated data and information should be publicly released by SDG&E. Conclusion SDG&E’s proposed redactions are thoughtful and limited, and support the objectives and functionality needed for the DRP and stakeholder processes. While some protestors object to SDG&E’s proposed redactions on the grounds that they are overbroad, unsupported, or fail to provide developers with needed information, none of the protests provide any evidence that the specific grid security risks and examples identified in AL 3210-E are not credible. In fact, while SDG&E provided detailed examples of risks and scenarios, the objections of several stakeholders were themselves unsupported and lacking in specifics. SDG&E requests that either the data redactions proposed in its AL 3210-E be approved as submitted, and if deemed applicable, a workshop be held in the future to vet this topic and decide if and how the approved redacted criteria should be modified. Sincerely, ________________________ CLAY FABER Director – CA & Federal Regulatory 4
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Public Utilities Commission cc: May 14, 2018 Edward Randolph – Energy Division Director Gabriel Petlin – Energy Division Dina Mackin – Energy Division Marc Monbouquette – Energy Division Chloe Lukins – Office of Ratepayer Advocates Sky C. Stanfield – Attorney for IREC Aaron M. Stanton – Attorney for IREC Jean Armstrong – Counsel for SEIA Tim Lindl – Attorney for Sunrun Alex J. Morris – CESA Kenneth S. White – Clean Coalition Service List R.14-08-013 5
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