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2023/04/12 Southern California Edison Edison Carrier Solutions - 2023 Emergency Operations Plan - Compliance ReportEDISON Gloria M. lng Senior Attomey Gloria.lng@sce.com April 12,2023 Robert Osbom, Director (robert.osbom@cpuc.ca.gov) Communications Division Califlomia Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 Submission of Emergency Operations Plan in Compliance with Decision 2l-02-029 Dear Mr. Osbom: Pursuant to Ordering Paragraph 5 and Section 5.9.2 of the Califomia Public Utilities Commission's (Commission) Decision No. 2l-02-029, Southem Califomia Edison Company (SCE) submits its 2023 Emergency Operations Plan for Edison Carrier Solutions. SCE's submission includes the Emergency Operations Plan, Emergency Contact Information, Emergency Preparedness Exercise Attestation, and Public Communications Plans. Pursuant to Decision No. 2 I -02-029, SCE is also providing a copy of its submission to the California Office of Emergency Services (CalOES), the local emergency response managers within our service territory,l and serviceresiliency@cpuc.ca.gov. Very truly yours, /s/ Gloria M. Ing Gloria M. lng GMl/odg cc: via email serviceresiliency@cpuc.ca.gov Nancy Ward, Director, CaIOES (nancy.ward@caloes.ca.gov) via U.S. mail SCE's Cities and Counties service list (CPUC Rule 3.2(b)) Because SCE does not know the identities ofthe local emergency response managers within our service tenitory, SCE is mailing a copy of its 2023 Emergency Operations Plan to SCE's Cities and Counties Service List that SCE uses pursuant to Rule 3.2(b) ofthe Commission's Rules ofPractice and Procedures. Because the distribution to our Cities and Counties is not electronic, SCE will be sending the 2023 Plan to these entities after the 2023 Plan is printed. Re P.O. Box 80{)2:.1.1 Walnul Crove A!e Rosemead.CalitbmiaqlTT0 (6:6rl0l-19s9 __l Via Email SOUTHERN CALIFORNIA EDISON R An ED/SON INTERNATIONAL o Company Edison Carrier Solutions 2023 Emergency Operations Plan Compliance Report April 12,2023 ANNUAL COMPLIANCE REPORT OF EDISON CARRIER SOLUTIONS APRTL 12, 2023 This report is submitted by Southern California Edison Company ("SCE") in compliance with Decision No. 21-02-029 to Adopt Wireline Resilience Strategies. This compliance report comprises the following: Compliance Statement: Summarizing SCE's compliance with Decision to Adopt Wireline Resilience Strategies. Edison Carrier Solutions Emergency Operations Plan Appendix A: Emergency Operations Plan Appendix B: Emergency Contact lnformation Appendix C: Emergency Preparedness Exercise Attestation Appendix D: Public Communications Plans COMPLIANCE STATEMENT Emergency Response Plan As part of SCE's continued commitment to effective emergency response, SCE maintains a portfolio of emergency response plans, has a robust emergency organization and routinely exercises its emergency response capability. Approximately 4,300 personnel have completed training in general and lncident Command System (lCS) specific positions in the past two years. ln addition, SCE conducts routine training with our field personnel on our emergency response processes, procedures and protocols. Compliance with CPUC Decision 2'l -02-029 Section 5.9.2 This Edison Carrier Solutions Emergency Operations Plan complies with CPUC Decision 21 -02-029 Section 5.9.2. o This plan is submitted to the Commission's Communications Division Director, CalOES, and local emergency response managers within the ECS service territory. o This plan includes: Appendix A: Emergency Operations Plan Appendix B: Emergency Contact lnformation Appendix C: Emergency Preparedness Exercise Attestation Appendix D: Public Communications Plans Routine Updates ln compliance with industry standards, emergency plans are validated and updated as necessary. The SCE Edison Carrier Solutions Emergency Operations Plan was revised in preparation fot the 2022 submission. The material was aligned to the phases of response, and actions were tied to execution checklists. lf Edison Carrier Solutions (ECS) makes substantive changes to its emergency operations plan, it will submit the revised plan to the CPUC within 14 days in compliance with CPUC Decision 21-02-029. Emergency Training and Exercises SCE has a robust training and annual emergency preparedness exercise program and ECS is incorporated as appropriate. Following the annual emergency preparedness exercise, SCE assesses the effectiveness of the exercise and modifies its emergency operations plans as needed. Communications Strategy ln response to CPUC Decision 21-O2-O29, ECS updated and enhanced its communications strategy. A copy of this strategy is attached in Appendix D. Annual Pre-Event Coordination Edison Carrier Solutions will participate in Pre-Event Coordination through exchange of contact information, and participatron in emergency exercises with external agencies, including CalOES. TABLE OF CONTENTS ANNUAL COMPLIANCE REPORT OF EDISON CARRIER SOLUTIONS COMPLIANCE STATEMENT...,.,,.,,., Emergency Response P|an ................ Compliance with CPUC Decision 21-02-029 Section 5.9.2....................................... Routine Updates.... Emergency Training and Exercises........ Communications Strategy.................. Annual Pre-Event Coordination APPENDIX A EMERGENCY OPERATIONS PLAN .,..,....,......,. PURPOSE ............. PLAN ACRONYMS ORIVERS ANO ASSUMPTIONS....,...,,. SCENARIOS AND POTENTIAL IMPACTS .............. Guarded lncident Scenario ................... Elevated lncident Scenario............. Substantial Outage Scenario................ Severe Outage Scenario....................... OBJECTIVES INCIOENT COMPLEXITY LEVELS AND ASSOCIATED ACTIONS,.,.,..,,................ tNctoENT coNcEPT OF OPERATIONS............................ ALIGNMENT WITH EXISTING EMERGENCY MANAGEMENT FRAMEWORKS ,.. DAMAGE ASSESSMENT ANO RESTORATION PRIORITIZATION.-.. Trouble Ticket Based Strategy.............. lmpact-Based Skategy ................. RESTORATION PRIORITIZATION,, High Priority Customers.......................... Training, Testing and Maintenance of The Plan .................. PHASES OF OPERATIONS.,.,,.,,,,,,,,,,,,,, PHASE 24: ACT|VAT|ON...................... PHASE 2B: lNlT|AL RESPONSE............................ PHASE 2C: SUSTAINED RESPONSE..................... PHASE 3: RECOVERY (DEMOBILIZATION).......... APPENDIX B EMERGENCY CONTACT INFORMATION:.. APPENDIX C EMERGENCY PREPAREDNESS EXERCISE ATTESTATION APPENDIX D PUBLIC COMMUNICATIONS PLAN Website and Social Media .................... Direct Contact Through Email and Telephone..................... Local Media, Local and State Elected Officials and Public Safety Stakeholders....... FCC..................... . CPUC..................... Notifications to Emergency Responders in Compliance with SB 670 ........................ Customer Education ............................ ll ii ii ii ii I 1 2 3 4 4 4 4 6 7 8 8 8 I I I aii Page 21 22 APPENDIX A EMERGENCY OPERATIONS PLAN PURPOSE The Southern California Edison Company (SCE) Edison Carrier Solutions (ECS) Emergency Operations Plan outlines a threat-specific strategy for mitigating, planning for, responding to, and recovering from disruptions to the system that cause an outage incident. Based on scenarios most likely lo occur, it is intended to guide how ECS will coordinate critical preparedness, response, and restoration activities before, during and after an actual telecommunications outage incident. ECS is a business unit within SCE. ECS is primarily established to provide commercial telecommunications services to telecommunications carriers, internet service providers, commercial mobile radio service providers, cable and satellite television companies, and enterprise customers. Service is provided to commercial customers only and ECS does not provide voice service or service to residential customers. This plan outlines the roles and responsibilities for lncident Management Teams (lMT) during response operations. lt is designed to help ensure safe and efficient restoration for any type of outage through consistent use of the lncident Command System, identification of applicable prioritization and restoration strategies, and the development of a common operating picture for communicating situational awareness to internal and external stakeholders. This plan does not supersede or replace existing procedures for safety, hazardous materials response, or other similar procedures adopted and in place, including and not limited to specific response plans prepared to address individual circumstances or to comply with regulatory requirements. The ECS incident response and associated emergency response and recovery plans are governed and/or informed by the following: . Federal Communications Commission's (FCC) network outage reporting regulationsl . CPUC telecommunications outage reporting regulations2 . Telecommunications Service Priority (TSP) Program for National Security and Emergency Preparedness3 o CPUC Decision Adopting Wireline Provider Resiliency Strategies D.21-02-029 . CPUC General Order Number 95 and General Order Number 128 147 C.F.R. 54.1-4.15 httos://www.qovi nfo.qov/aDo/deta ils/CFR-201 5{itle47-vol1 iCFR-201 5{itle47 -vol1 -oar14 2 CPUC General Order 133-C Rules Governing Telecommunications Services 3 47 C.F.R. 964, Appendix A Page | 1 PLAN ACRONYMS AREP AgencyRepresentatives BRDM Business Resiliency Duty Manager CFR Code of Federal Regulations CMC Crisis Management Council DWDM Dense Wave Division Multiplexing ECS Edison Carrier Solutions EOC Emergency Operations Center FCC FederalCommunicationsCommission's ICS lncident Command System ICT lncident Communications Team IMT lncident Management Team IST lncident Support Team LNO Liaison Officer SCE Southern California Edison Company SOC State Operations Center SEMS Standardized Emergency Management System NIMS National lncident Management System TCC TelecommunicationsCommand Center TTC TransmissionTelecommunications Organization Page | 2 ORIVERS AND ASSUMPTIONS ECS is actively engaged in managing potential reliability and safety impacts from incidents that may cause disruption to its commercial telecommunications system by prioritizing damage assessment, restoring critical infrastructure and communicating with internal and external stakeholders to increase situational awareness. Specific drivers and assumptions for these events include, but are not limited to, the following: o Damage assessment operations will be performed when safe to do so. . Restoration activities may need to be prioritized based on response operations. . Organizational units may be required to modify their daily operations to assist with incident management. . Business Continuity and/or Disaster Recovery Teams may be activated for incident response operations. . Local EOCs may be activated to coordinale city, county and state government response to anECS incident. . SCE IMT and ECS personnel may be deployed to communicate and coordinate activities with city, county, and state EOCs where necessary. Page | 3 SCENARIOS AND POTENTIAL IMPACTS The ECS Emergency Plan uses four incident complexity levels: Guarded, Elevated, Substantial, and Severe. These complexity levels are established for the ECS commercial telecommunications as a whole. The overall incident complexity level is based on an aggregation of individual trouble ticket information that has been augmented with consideration for unrelated widespread outages such system-wide interruptions. ECS will base all prevention, mitigation, preparedness, response, and recovery operations related to outage incidents on the following scenarios and potential impacts based on complexity. Guarded lncident Scenario A guarded incident is typically localized to one or more circuits with a single cause and normal resources are sufficient to manage response and recovery activities. Guarded incidents are frequent, occurring several times a month. Characteristics include: . Customer interruptions: "Standard" ECS customer outage with clear recovery path (fiber cut, equipment failure, and TCC/ECS working to resolve and communicate with customer). Customers may be'hard down'without service or 'non-redundant' with a backup circuit still functioning or in a ring with a secondary pathway. o Restoration: There are sufficient field personnel, restoratron technical resources (fiber optic cable, equipment, telecommunications cards, optics, etc.) and other technical or operations specialist resources. . Majority of customers are typically expected to be restored in less than 24 hours. Elevated lncident Scenario An elevated incident is typically spread over multiple systems or in a more complex isolated incident that requires additional resources to manage response and recovery activities. Elevated incidents are experienced only a few times in any one year. Such incidents can be characterized by multiple ECS customers'hard down'or critical systems impacted resulting in: . Customer interruptions: Multiple customers carrying critical information/data impacting their businesses or the customers of their business. Such traffic may include cellular traffic, business data, first responder networks or other businesses where telecommunications services are critical to their operations. . Restoration: Sufiicient field personnel, restoration technical resources (fiber optic cable, equipment, telecommunications cards, optics, etc.) and other technical or operations specialist resources are available or may be reallocated to provide assistance with extended shifts for personnel. ECS Tier-3 support may potentially reroute customer traffic to other cables and/or systems based on priority and availability of fiber and network resources. . TCC telephone bridge with ECS Tier-3 and other shared partners may be enabled. ECS leadership (via escalations) may be engaged as well to assist in managing customer expectations and communication. . Majority of customers are typically expected to be restored in less than 48 hours. Substantial Outage Scenario A substantial incident is typically erther an incident with escalating consequences affecting multiple systems or a severe-intensity isolated incident. Such incidents are rarely experienced on a yearly basis, occurring on average once or twice every ten years and are characterized by an extremely high number of outage related incidents resulting in: o Customer interruptions: Complex ECS technical issue(s), customer issue(s) or incident requiring full ECS management and shared partner engagement for resolution. Examples include ECS (cell sites, first responder network, etc.)maior hub down, or maior fire riskinq critical ECS circuits Page | 4 SCEtilARIOS An IMT may be initiated and in place to manage the response to the outage(s) and coordinate restoration. Restoration: There may be insufficient field personnel and other constraints related to equipment spares, telecommunication cards, optics, or fiber optic cable (and/or field equipment). Additional assistance from other shared partners/vendors maybe required. Majority of customers are expected to be restored in less than 72 hours. Severe Outage Scenario A severe emergency or incident may require additional assistance if the resources required to respond exceed the available SCE/ECS resources and restoration may be prolonged beyond 72 hours. Such incidents are extremely rare and may cause such significant damage to the system resulting in: . A company-wide need to focus on restoration efforts. . Customer interruptions: Major SCE event or Southern California lncident which engages the SCE IMT and affects critical ECS telecommunications systems, customers, and/or traffic. ECS engages the IMT and participates in the IMT as appropriate until issues resolved/stand down. . Restoration: Potentially have insufficient field personnel and other constraints related to equipment spares, telecommunication cards, optics, or fiber optic cable (and/or field equipment). Additional assistance from other shared partners/vendors may be required. Service restoration is based on prioritization as described later. o Restoration may be prolonged beyond 72 hours. . Required replacements for equipment and cable damaged may exceed those available. o Potential safety and/or health concerns. Service outages that may pose a life safety risk to critical customers or essential services POTENTIAL IIYIPACTS Common scenarios may include the following: . Fiber Optic Cable Cuts - Damage directly to a cable that can be caused by tree trimmer errors, contractor digging, rodents, etc. Cables are also damaged indirectly when the supporting pole is damaged due to fire, lightening, vehicle hit pole, etc. . Electronics Failure - ln telecommunications, the service provider (ECS) utilizes electronic equipment to serve customers. ln this environment, equipment failure may cause service interruption. The electronics equipment may include: equipment chassis, modules/cards, and oPtics. . Cyber-Altack - SCE has its own lT department that manages cybersecurity risk, prevention, detection, and mitigation. ECS works closely with the SCE cybersecurity team to monitor and manage cyber-attacks or other threats. . Fires - The California fire season typically begins during the summer and peaks in the fall, but fires are becoming a more frequent threat year-round. Because fires often affect areas that are relatively inaccessible, outage lengths are usually much longer compared to other types of severe events. Ivlost fire recovery efforts and costs involve rebuilding and repairing cables and restoring telecommunications service after the fire has passed through affected areas and SCE has rebuilt poles and other aboveground structures. . Extreme Environmental rssues - Extreme environmental (and weatheo challenges such as earthquakes, lightning storms, significant rainstorms, cold weather including snow and sleet, and windstorms have the potential to cause extensive damage. Any of these scenarios can limit ability to respond to outage situations. Page | 5 Page | 6 OBJECTIVES The following objectives for incident management within the ECS commercial telecommunications system have been identified: . Maintain the safety of customers, employees, contractors, flrst responders and the public . Maintain effective communications with internal and external stakeholders (employees, customers, the public, first responder and emergency management agencies, and public officials) on potential impacts of the incident . Perform safe and timely damage assessment of impacts to ECS infrastructure . Prioritize restoration activities of ECS infrastructure . Conduct safe and efficient restoration of critical ECS infrastructure . Monitor conditions within the telecommunications system and the need for potential mitigation activities . Attempt to notify customers of potential outages and provide on-going outage updates . Comply with all identified regulatory requiremenls . Consider impacts to the environment INCIDENT COMPLEXITY LEVELS AND ASSOCIATED ACTIONS "Standard" ECS customer outage with clear recovery path (fiber cut, equipment failure, and TCC/ECS working to resolve & communicate with Customer) Level 3 ELEVATED Multiple ECS customers down (or critical system - DWDM) with extended outage timing or unknowns related to resolution. Management escalation and engagement within ECS and TCC/TTC to ensure outage or service issues are resolved in a safe, productive manner A rare and unanticipated emergency with the potential to do, or in the process inflicting irreparable and severe harm to the commercial telecommunications network. The most severe type of incident. Examples include a major SCE event or Southern California lncident which engages the SCE IMT and affects critical ECS systems, customers, and/or traffic. ECS engages the IMT and participates in the SCE IMT as appropriate until issues resolved/stand down. Level 4 GUARDED Page | 7 Level 2 SUBSTANTIAL lncidents with the potential to result in substantial harm to the commercial telecommunications network, but there is a higher level of familiarity or expectation. This may present itself as complex telecom technical issue(s), customer lssue(s). or an incident requiring full ECS management and shared partner engagement for resolution (e.9., ECS major hub down, or major fire risking critical ECS backhaul circuits (cell sites, first responder network, etc.)). The IMT is implemented - for full response and management engagement. Level 1 SEVERE INCIDENT CONCEPT OF OPERATIONS ALIGNMENT WITH EXISTING EMERGENCY MANAGEMENT FRAMEWORKS Outage events can pose coordination and communication challenges for our local Public Safety Partners. Therefore, SCE will actively support and engage stakeholders through existing State and Federal emergency frameworks for collaborative planning and response. This engagement is intended to prevent duplicative effort, increase situational awareness, standardize response operations, and integrate existing outreach and collaboration whenever possible. SCE standardizes planning and response frameworks with Public Safety Partners for outage events through alignment with the California Governor's Office of Emergency Services, Standardized Emergency Management System (SEMS) guidelines. This alignment includes implementing an lncident Management Team (lMT) structure to manage outage events. SCE's Business Resiliency organizational unit is responsible for the creation, implementation, maintenance, training, and testing of SCE's company-wide emergency plans, and provides guidance on emergency plans to ECS. lts staff also works to create relationships with state and local governments, Public Safety Partners, and other community stakeholders before events occur to increase communication and collaboration during PSPS events. SCE maintains a direct line of communication with impacted communities, the Safety and Enforcement Division of the Commission, CalOES, the California State Warning Center, and the California Utilities Emergency Association, as applicable to any emergency response operation. SCE utilizes specialized Fire Management staff to monitor, respond to, and report on all fires affecting or having the potential to affect SCE and ECS infrastructure. These personnel represent SCE by serving as a Cooperatod in the field fire incident management structure. Fire Management staff assist in coordinating SCE's response to fires by providing information to manage the bulk electric system, repairing damage, restoring the electric system, restoring the wireline system, and providing safe access to begin restoration work. These personnel maintain close working relationships with fire and emergency management agencies throughout the service territory and serve as consultants and subject matter experts on fire risk management. During times of response, SCE staff may also act as an Agency Representative (AREP), operating as a liaison between SCE's lncident Management teams and the affected communities. AREPs work to identify outages, real and potential issues associated with those outages, and information requests regarding restoration. This relationship allows for increased situational awareness to make informed decisions regarding evacuations, necessary fire-fighting operations and critical restoration times for essential and critical use facilities. SCE also makes every effort to provide space in its Emergency Operations Center for representatives from CalOES, Public Safety Partners, and water and communications infrastructure providers when requested. SCE also aligns lncident Command System response with Federal structures to rnclude use of Federal lncident Management team structures during outage events. This is a fundamental form of management, and it enables incident managers to identify the key concerns associated with the incident, often under urgent and/or challenging conditions, without sacrificing attention to any component of the command system. This alignment allows SCE to respond to both single and multiple incidents simultaneously if need be, while still effectively scaling operations and maintaining appropriate response levels. DAMAGE ASSESSMENT AND RESTORATION PRIORITIZATION ECS may need to address more than one outage incident concurrently and may employ different strategies for assessing damage and restoring service based on customer impact, scope, and complexity of each incident. ln smaller, more isolated incidents, ECS typically employs the standard trouble ticket-based strategy that it uses under routine outage circumstances" As described below, this strategy is not effective or efficienl in larger incidents where there is an overwhelming volume of trouble tickets. When incidents are larger, ECS moves to an impact-based strategy where repair priorities are assigned by areas and circuits. This is a tactical decision made during the planning process for a given operational period and documented in the lAp. The two strategy 4 A federal, tribal, state, or local agency that participates with another agency(s) in planning and conducting fire oremergency managemenl projects and activities as defined by the National Wildland Coordination Group (NWCG). Page | 8 types, trouble ticket and impact-based, can be used together as needed during the course of an event. Trouble Ticket Based Strategy Trouble ticket-based restoration is most frequently applied during less complex incidents where the number of trouble tickets is within the capacity of the available workforce to efficiently process and complete. Trouble ticket-based strategies may also be useful during less complex, distributed incidents where there is not a significant amount of physical damage experienced by the system. lt is also useful before and concurrently with the initial damage assessment before the full extent of the damage has been discerned. The trouble ticket-based restoration strategy is used when there are a relatively small number of trouble tickets. Under this strategy, day-to-day restoration processes monitor, locate, and repair faulty equipment or cables. The TCC (Telecom Command Center) prioritizes trouble tickets based on response criticality and resource availability. Trouble ticket-based restoration is very effective when the instances of damage are not substantial and when the number of trouble tickets allows for a response in an orderly manner. The degree of effectiveness of this type of restoration strategy may be diluted when the physical damage is substantial. ln such an instance, the time necessary to restore a specific trouble ticket is not easily incorporated into the analysis, which prioritizes and assigns work. Consequently, during significant incidents where there is widespread damage resulting in numerous trouble tickets with physical damage, an impact-based restoration strategy may be more appropriate to optimize the restoration effort. lmpact-Based Strategy lmpaclbased restoration strategy is used when the number of trouble tickets exceeds the ability to assign work on an individual trouble ticket basis. Work is coordinated with SCE utility telecom restoration and assigned to crews based on impacUurgency for restoration and prioritized rather than through evaluation of individual trouble tickets. Work is priorrtized based on considerations such as impacted service criticality, impacted service level ('hard down' vs. non-redundant) and magnitude of telecom traffic impacted (how many customers are impacted by the specific outage cause). The impact-based restoration strategy focuses executing the outage restoration work on restore critical services that are'hard down' ahead of other outage types that are less critical (speed degradation, restoration of non-redundant to full redundant, etc.). This type of restoration strategy capitalizes on directing multiple resource types, including damage assessors, first responders, SCE telecom restoration crews under one authority, thereby, optimizing their efforts. RESTORATION PRIORITIZATION Due to the wide range and nature of incidents, ECS has identified guidelines to restore both the most critical circuits as quickly as possible while continually prioritizing public health and safety. With safety of the public and employees as our topmost priority, restoration work needs to be performed in the most efficient manner possible while also maintaining critical infrastructure, service obligation, and customer satisfaction considerations. High Priority Customers ln order to identify customers that provide essential public service as well as critical infrastructure customers who have been pre-identified to be imperative to broader public safety, SCE has developed a method which prioritizes addressing outages in the system based on a combination of several factors, including: . Pre-identified criticality based on facility/telecom traffic (first responders, law enforcement, government agencies, hospitals/critical care facilities, municipalities, general cellular traffic, general business traffic, etc.) . Criticality determined by length of time without service or service degradation level (unprotected, performance degradation,'hard down,' etc.) . Number of customers affected Page I I Training, Testing and Maintenance of The Plan Annual updates to the Emergency Plan are socialized through SCE's established training and exercise program. The Emergency Plan is tested through an annual exercise series created to identify gaps in planning to allow for continuous improvement. ECS also complies with all CPUC requirements through annual updates and submittal of the Emergency Plan as required. Page | 10 Response RecoveryPre-lncident Activation lnitial Response Sustained Response RecoveryNormal Operation PHASES OF OPERATIONS ECS will utilize the following phased approach as the foundation for outage incident management for Substantial and Severe Scenarios: Phase l: Normal Operations Outlines the mitigation and preparedness programs regularly practiced throughout the organization. Phase 1 is ongoing and informed by risk assessment and identified mitigation needs. Phase 2A: Activation Outlines the actions taken during the beginning an event, with a focus on activating personnel and gathering initial situational awareness and ends once lncident Command establishes operational control over the incident. Phase 28: lnitial Response Details the actions of the IMT in the early response operation, focusing on situational awareness and establishing a regular response cycle allowing all teams to coordinate effectively. Phase 2C: Sustained Response Outlines the continuing activities of the IMT once operational control, a regular operational cycle and situational awareness have been established. Phase 3: Recovery Outlines the activities of key personnel following the end of an event. This includes analysis of an affected system to determine the potential for ongoing issues, identifying indicators to inform mitigation and preemptive measures, and developing a schedule for continued monitoring for post-incident issues. 1 2A 2B 2C 3 Page | 11 PHASE 2A: ACTIVATION Pre-lncident Recovery Normal Operation Activation lnitial Response Sustained Response Recovery lndicators a Critical lnformation irements:. ldentification of possible alrisk systems . Outage damage identification, assessment and impact (systems and customer traffic) . Status of any additional indicators (fires, vehicle incidents, tree trimming work, etc.) . ldentification of available field resources and supplies End-State Conditions for Phase 24: Activationo IMT responds to the Emergency Operations Center (EOC) . lncident Command personnel are activated, deployed, and responding under the ICS o lnitial safety concerns have been assessed and protective actions are being implementedas appropriate (move to Phase 28: lnitial Response) --oR-- The BRDM with input from subject matter experts determines the incident nolonger poses a significant threat to SCE and ECS services and no IMT is activated (return to phase l: Normal Operations) o Role Res onsibilit CE Watch Office tr Send Critical lncident Report (as needed) tr Distributes update on Watch Office Daily Report usiness Resilienc uty lvlanager BRDM) Provide support to IMT and assist with coordinating response efforts Make contact with impacted jurisdrctions (Local, State, Federal) lnterface with the Officer in Charge Officer in Charge (OlC) and the Crisis Management Council (CMC) Review scheduled lT outages and coordinate rescheduling with lT Branch Director tr tr tr D ommander (lC) lncident uate the needs of the incident and define the appropriate organizational structure for the incident Assess the need to activate supplemental emergency action and/or business continuity plans for different regions of the SCE service territory and critical applications tr tr Eval rcer Pto Public lnformation lmplement Public Communications Plan (Appendix D)D Phase 2A: Activation Execution Checklist Page | 12 Response I 2A 28 2C 3 Outage occurs and TCC becomes aware due to alarms or trouble ticket influx by customer(s) Liaison Officer (LNO)tr Determine need to use SCE Alert process or other means to inform elected officials ! LNO establish contact with EOCS ! Monitor potential health and safety risks at external locations where SCE personnel are operating tr Evaluate and report on potential issues related to projectedwork Safety Officer (soF) tr ldentify presence of environmental resources (biological, cultural,and waters)Environmental Officer Operations Section Chief (OSC) D Determine resource needs and arrange to have crews on sitefor anticipated impacts tr Stay informed restoration strategy and support efforts through allocation and assignment of resources tr Review system abnormal circuit conditions for potential return to service tr Coordinate with the Air Operations Branch Director to allocate air operations resources to support aerial surveys and the transportation of mission critical personnel n Coordinate with the ECS sales team to ensuresystems are in place to implement macro-messaging as necessary following the upcoming event D Coordinate with the OSC to assess the availability of SCE and contract resources to meet stafting limitations for all affected OUs Planning Section Chief (PSC) tr lnventory assessments are conducted in the forecasted impact regionsto ensure critical assets and equipment are available/ordered, and able to be in place prior to the event tr ldentify operational resource coordination points (e.9., laydown yards, PODs, etc.) tr Assess the availability of fuel resources and coordinate the provision of fuel for SCE and contractor vehicles, equipment, and aircraft D ldentify available emergency generators tr Assess lodging and meals availability and begin securing necessary accommodations at the discretion of the Operations Section Chief tr Reconcile ongoing travel and transportation limitations withinimpacted areas Logistics Section Chief (LSC) Page 113 Phase 2A: Activation Execution Checklist: PHASE 28: lNlTlAL RESPONSE Pre-lncident Response Recovery Normal Operation Activation lnitial Response Sustained Response Recovery lndicators MT activated and operating at the Emergency Operations Center Customer, local government and public safety agency nolifications and coordination are being conducted IST/I Critical lnformation R uirements:. ldentification of impacted customers, circuits, and systems . Damage modeling o Status of any current fire(s) burning in or toward ECS facilities . Status of available field resources o Status of the system and any constraints End-State Conditions for Phase 28: lnitial Res nse:. Communication established between IST/IMT and field teams . Early damage assessments have been conducted and common operating picture has been established . Resource requirements have been reviewed and support has been requested ' SCE agency representatives are communicating with affected local governments, public safetypartners and customers, gathering situational awareness and prioritizing restoration requests . Requests from field resources for support personnel have been conducted (move to phase 2C : S u sta i n e d Response) --oR-- o The BRDM, with input from subject matter experts as needed, determines that the threat toscE has lessened and activation of teams is no longer necessary (move back to appropriatePhase) Role Responsibility CE Watch Office tr lncludes status updates in the Daily Report tr Sends Critical lncident Report BRDM Business Resilienc Duty Manager Works with IST/IMT lead to provid and coordinate response efforts e continual situational awareness updates! S IMT lncident ommander tr tr Works with Operations Section to determine resource requirements Actively manages the incident Phase 28: lnitial Res ponse Execution Checklist: Page | 14 1 2A 2B 2C 3 Public lnformation Officer (PlO) D Update messaging in accordance with Public Communrcations Plan (Appendix D) Liaison Officer (LNo) D Contact county EOCs and emergency response organizations and coordinate the deployment of SCE representatives where appropriate tr Coordinate with external response structures to expedite orwaive permitting requirements. D Communicate high-level restoration strategies and customer impacts tl Provide county/city restoration needs back to OSC for possible prioritization tr Monitor potential health and safety risks where SCE personnelare operating tr ldentify potential health and safety associated with SCE facilities and notify SCE personnel, the public, and local authorities where appropriate tr Communicate need to document and report all safety incidents tr Coordinate the production and distribution of employee notifications outlining safety information and providing guidance on initial actions Safety Officer (soF) Environmental Officer (EOF) D Develop strategies and priority for avoiding and minimizing environmental impacts n Coordinate with OSC to implement environmental mitigation strategies tr ldentify environmental permits required D ldentify if impacted area is on public land jurisdiction. Provide emergency notifi cations to government agencies. tr Coordinate with DOCs and CA to ensure critical care and medical baseline customers have been identified and notified tr Coordinate with the TCC to determine status of infrastructure and assess impacts on restoration strategy D ldentify focus areas for further damage assessment tr Stay informed of TCC restoration strategy and support efforts through allocation and assignment of resources tr ldentify critical resource gaps and mitigate through contractors. Coordinate all MA requests with the Business Resiliency Duty Manager (BRDM) L Develop a system restoration strategy, prioritizing the recovery ofassets critical to re- establishing services throughout the ECS service territory ! Ensure resources are identified and assigned to clear hazards with imminent danger as reported by the public and government agencies tr Determine if system restoration should be executed by impaclbased or ticket- based tr Establish damage assessment strategy D Coordinate with the Air Operations Branch Director to allocate air operations resources to support aerial surveys and the transportation of mission critical personnel tr Reconcile ongorng emergency repairs with affected locations and provide resource needs and restoration updates D Coordinate with the ECS sales team to implement macro messaging for all Operations Section Chief (OSC) Page | 15 Phase 2B: lnitial Response Execution Ghecklist: customers without accurate restoration times Planning Section Chief (PSC) tl Coordinate with the OSC to assess the availability of contract resources to meet staffing limitations for all affected OUs Logistics Section Chief (LSC) tr ldentify operational resource coordination points (e.9., laydown yards, PODs,) tr Assess the availability of fuel resources and coordinate the provision of fuel for SCE and contractor vehicles, equipment, and aircraft tr Assess lodging and meals availability lT Tech Spec D Assess damage to all systems that support mission critical facilities/operations (e.9., contact centers, TCC, DOCs, Switching Centers, GOC, ESOC, etc.) D Develop a long{erm lT restoration strategy, aligning restoration priorities across the company tr Develop restoration strategy for critical applications tr Coordinate with the BRDM and lT Branch Director Phase 2B: lnitial Response Execution Checklist: Page l'16 PHASE 2C: SUSTAINED RESPONSE Pre-lncident Normal Operation Activation lnitial Response Sustained Response Recovery lndicators IMT has established an operating picture and incident is managed until recovery begins Recurring response cycle is being maintained Resources are being integrated into response operations at the field level Ongoing internal/external communications regarding event are being conducted Critical lnformation Requirements. Ongoing identification of possible at-risk circuits and systems . Status of any impacted circuits or systems o Damage modeling . Status of any current fire(s) burning in or toward ECS facilities . Status of available field resources . Status of the system and any constraints o IMT Availability End-State Conditions for Phase 2C: Sustained Response o Field operations concentrate on restoring normal services . Triggers for transitioning to field operations have been identifled and met o IMT has demobilized o ECS is no longer at risk for continued disruptions due to the incident ResponsibilityRoletr Coordinate with the SOF to implement a 16/8 rotation to support safe operational activity tr Stay informed of restoration strategy and support efforts through allocation and assignment of resources tr Ensure resources are identified and assigned to clear hazards with imminent danger as reported by a public agency and/or the public n Ensure the execution ofthe lT restoration strategy, aligning restoration priorities across the company tr Transition out of macro messaging by developing accurate service restoration times and coordinating with the ECS sales team to close out existing macro messages perations Section hief (OSC) Planning Section Chief (PSC) ! Develop a demobilization plan, defining the roles and responsibilities of a recove nse teamtaskforce lo continue o erational activi after the res nse Execution ChecklistPhase 2C: Sustained Res Page | 17 Response Recovery 1 2A 2A 2C 3 demobilizes Public lnformation Officer (PlO) Safety Officer (soF) tr Monitor potential health and safety risks where SCE personnelare operating tr ldentify potential health and safety risks associated with ECS facilities and notify SCE personnel, the public, and local authorities where appropriate tr Monitor for "fatigue" for long-term '16/8 rotations tr Ensure updated safety notifications are distributed throughoutthe incident to inform SCE personnel of existing or evolving risks Environmental Officer (EOF) tr Monitor ground disturbing activities in areas with environmental resources tr Ensure proper waste management in identified laydown yard(s). Wood placed in wood bins. Wire and metal placed into salvage bins. tr Ensure environmental permits obtained and emergency environmental notifications provided to agencies Phase 2C: Sustained Res onse Execution Checklist Page | 18 tr Update messaging in accordance with Public Communications Plan (Appendix D) PHASE 3: RECOVERY (DEMOBILIZATION) RecoveryPre-lncident Response Activation lnitial Response Sustained Response RecoveryNormal Operation lndicators. lncident has subsided, and telecommunications services are being restored . Observations in the field report no imminent threat and forecasts indicate that hazardous conditions have passed and are not expected to increase for a period of 72 hours ormore Critical lnformation uirements Status of circuits and any ongoing repairs End-State Conditions for movi to Phase 3A: Recove. Field operations concentrate on restoring normal services . Triggers for transitioning to a recovery task force have been identified and met . ECS IMT has demobilized o The recovery task force is coordinating response activity with operational control managed at the district level o ECS is no longer at risk for continued disruptions due to theincident .o ResponsibilityRole Watch Office ! lnforms CMC of demobilization of EOCBusiness Resiliency Duty Manager (BRDM)tr Deactivates based on information from the BRDMCMC Coordinates with local government, public safety agencies and N demobilize SCE resources at community locations as appropriate GOs toLiaison Officer tr Formulates long-term strategy on recovery to include both short{erm and long-term restoration strategies for impacted areas as necessary tr Facilitates a conference coordinalion call with OPS Director to validate that DEMOB criteria have been met and that DEMOB is appropriate. D Establishes triggers for re-activation of the IMT and communicates them to the Watch Office, ECS Sales, and the Plans Section Chief for inclusion in the DEMOB plan lncident Commander D Creates DEMOB PlanPlanning Section Chief ! Addresses long term repairs for damaged systems in DEMOB plan ! Demobilizes field observers and additional mitigation resources tr Works with the ECS sales team to discontinue macro-messaging as required Operations Section Chief Phase 3: Recovery Erecution Checklist: Page | 19 312C2A29 n Sends Critical lncident Report n lncludes status updates in the Daily Report APPENOIX B EMERGENCY CONTACT INFORMATION : At least annually, ECS will submit emergency contact information in a form prescribed by the CPUC's Communications Division Oirector. ECS uses the SCE Watch Office for emergency activation and notification. The Watch Office can be reached al (626) 8124286 or by watchofflce@sce.com. The Watch Office has access to emergency contact information and can provide personnel that includes individuals who will be able to serve as the State Operations Center (SOC) liaison and can be present twenty-four (24) hours a day, seven (7) days per week in the SOC, when requested by CalOES, during emergency response events. The ECS SOC liaisons are trained in emergency response, in accordance with Standardized Emergency Management System (SEMS), have working knowledge of ECS operations and business processei, and are informed of the impacts of disasters on the ECS network. ECS provides its emergency operations plans and emergency contact information to state emergency response organizations and local emergency response organizations within its commercial telecommunicalions service territories annually. Page | 20 APPENDIX C EMERGENCY PREPAREDNESS EXERCISE ATTESTATION SCE has trained its commercial telecommunications system personnel in the proper procedures for implementing its emergency plan. ECS personnel participate in the annual SCE-led emergency preparedness exercise to test its emergency procedures. Following the annual emergency preparedness exercise, ECS assesses the effectiveness of the exercise and modifies its emergency operations plan as needed. Page I 2'l APPENDIX D PUBLIC COMMUNICATIONS PLAN Website and Social Media As soon as reasonably possible, at the onset of a disaster (Substantial or Severe lncident Scenario), ECS shall post on its public website, www.edisoncarriersolutions.com, and update at least daily: . A map of outages and service impacts, . A description of any outage impacts in the specified areas, and . The expected restoration time ECS will post a link on all its social media accounts a link to the outage maps page on the website under www. edisoncarriersolutrons. com Direct Contact Through Email and Telephone At the onset of a disaster (Substantial or Severe lncident Scenario) or PSPS event, SCE will send emails or speak telephonically to impacted customers, ln the event of a wildfire, as well as actual and potentlal PSPS, SCE will email customers infier 2 and Tier 3 High Fire Threat Districts a general notification about potential impacts to their service. SCE will follow Customer Outreach Best Practices according to D.19-08-025 Ordering Paragraph I by contacting these customers in their preferred language. SCE will email all customers requesting updates to their contact information used to receive emergency and outage notices annually in advance of fire season each year. Local Media, Local and State Elected Officials and public Safety Stakeholders Outreach to Local Media, Local and State Elected Officials and Public Safety Stakehotders will be coordinatedthrough the scE IMT in the case of substantial and severe incident scenarios. FCC The FCC will continue to be notified in accordance with FCC 47 CFR, part 4. CPUC The CPUC will continue to be notified in accordance with CpUC GO 133-C Section 4. Notifications to Emergency Responders in Compliance with SB 670 SB 670 requires all providers whose telecommunication service provides access to g-1-1 to notify CaIOESwhenever a community isolation outage occurs, within 60 minutes of discovery. ECS does not provide 9-1-1service and SB 670 does not apply. Customer Education The customer education requirements do not apply to ECS because it does not provide service to residentialcustomers. Page | 22 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Broadband Infrastructure Deployment and to Support Service Providers in the State of Califomia. Rulemaking 20-09-00 I I hereby certify that I, Sasha Chavania , have this day served a true copy ofSouthern California Edison Company's Advice Letter 4955-E regarding Route Fire - Information in Compliance with Ordering Paragraph I of Decision 2l-10-020 on the cities and counties and govemment agencies as specified in Rule 3.2(b) of the Commission's Rules of Practice and Procedure. SCE is using the Rule 3.2(b) service list to comply with the service requirements set forth by the Califomia Pubtic Utilities Commission in Decision 2l-10-020 fbr Tier I Advice Letters that SCE must submit to the Commission when there is a disaster declared by the Califomia Govemor or United States President and a SCE facility has been damaged or there is a service outage. Service was effected by placing copies in properly addressed, sealed envelopes and causing such envelopes to be delivered via United States mail with first-class postage prepaid. I declare under penalty olperjury that the loregoing is true and correct. Executed on April 20 , 2023, at Rosemead, Califomia. Sa./za, Signature Sasha Chavarria Name Mailing Clerk Position/Title CERTIFICATE OF SERVICE