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					   Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5



                      BEFORE THE PUBLIC UTILITIES COMMISSION
                           OF THE STATE OF CALIFORNIA


Order Instituting Rulemaking to
Consider Smart Grid Technologies
Pursuant to Federal Legislation and on                            R.08-12-009
the Commission’s own Motion to Actively                    Filed December 18, 2008
Guide Policy in California’s Development
of a Smart Grid System.




                      Notice of Motion and Motion to the
                   California Public Utilities Commission


      Motion to Establish a Minimum Level of Competence for any and all Digital
Information controlling or generated in SmartGrid systems falling under the CPUC’s
                                      regulatory control




Abstract:
This is a motion to the CPUC to accomplish two milestones to protect the End-Users
(Consumers) of the SmartGrid system by establishing a minimum standard of competence
for information generation by SmartGrid components operated as part of any Utility in the
State of California. This is specific to the Digital Evidence applicability that output from the
SmartGrid’s operations produces and to how it is maintained.




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     Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5




Table of Contents
Notice of Motion and Motion – Rulemaking on reliable evidence requirements......................... 3
1.    Introduction ................................................................................................................................................. 3
   The “all Digital Evidence must meet minimum Court Standards” Motion ................................. 3
2.    Discussion ..................................................................................................................................................... 4
   SmartGrid Evidence Standards ................................................................................................................... 4
   CPUC Open Rate Models ................................................................................................................................ 9
   Other CPUC Dockets this affects .............................................................................................................. 10
   Investor Owned Utilities (IOU’s) and Providers each qualifying their operating Security
   Models ............................................................................................................................................................... 11
   Breaking up the SmartGrid model – defining the CPE Demarcation point ............................. 11
   The first example – The L1 GPS System ............................................................................................... 12
   Motion to take Notice that L1 GPS fails to meet minimum security as a time source ........ 13
3.    Conclusion ................................................................................................................................................. 20
   Motion 1: Certichron’s Motion for an issuance of a Rule regarding that “SmartGrid
   systems must produce evidence meeting the defined standards for court admissibility”21
   Motion 2: Certichron’s Motion for an Order mandating a Provable level of Integrity in
   Digital SmartMeter’s Evidence Capture models ................................................................................ 22
   Summary........................................................................................................................................................... 23
Appendices – GPS jamming and Spoofing Technologies .................................................................... 24
   GPS Jammers are commercially available from China and other sources .............................. 24
   Sample GPS Jammer Schematic – Build your own for under $50 USD ..................................... 24
   Hacking GPS and Satellite Navigation, the Potential Criminal Payoffs ..................................... 26
   Car thieves using GPS 'jammers' ............................................................................................................. 29
   Jamming of GPS signals threatens vital services ............................................................................... 31
   USCG: Moss Landing California “Jamming based GPS-ouatage”.................................................. 33
Appendices – US Evidence Rules and Spoliation of Data/Evidence. .............................................. 35
   Admissibility of ESI into Evidence: Lorraine v. Markel .................................................................. 36




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   Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5




Notice of Motion and Motion – Rulemaking on reliable evidence
requirements

                 Notice of Petition (Motion) to adopt, amend, or repeal
                   a regulation pursuant to Pub. Util. Code § 1708.5.

This is a motion to the California Public Utilities Commission (CPUC) to in its Rulemaking
Operations to formally establish two new milestones under R.08-12-009 in protecting the
End-Users (Consumers) of the SmartGrid system, and that is for a Ruling to order that
“any and all systems deployed as part of a SmartGrid system must meet the minimum
standards for competent evidence already set in both the Courts of the State of California
and in the US Federal District Court so that matters crossing State jurisdictional boundaries
can be properly adjudicated when necessary”.


This motion is submitted by electronic filing for review before the PUC and is served
electronically throughout the 08-12-009 service list.


Todd S. Glassey, CISM CIFI
Certichron inc
TGlassey@Certichron.COM




   1. Introduction

The “all Digital Evidence must meet minimum Court Standards” Motion
Since the Energy Marketspace enabled by SmartGrid is based in allowing the Consumer
open access to Power and Utility Providers by turning the Grid itself into a Last-Mile type
operation, and to mirror the Telecom Grid’s operations to an extent, this fundamental
statement of evidence competence is necessary.




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Traditionally, technology has refused to conform to Law and Process

As underlying history, these standards of evidence are oft times ignored by technologist as
‘inconvenient’ and in this instance where a system is being fielded to serve the public trust
and interest, these issues of competence in the evidence model for all digital systems must
be enforced to protect the consumers and the People of the State of California from
unintentional errors and potential purposeful frauds which could be perpetrated against
them through Time of Use (TOU) billing errors.



Technology in the case of SmartGrid must implement the Rule of Law

To ‘fix’ this potential for problems the technology used in the SmartGrid must either
produce competent evidence on its own or through being leveraged through some other
process to mitigate the design flaws or fundamental weaknesses which would appear
through the Evidence Audit of the technologies and their operation.


   2. Discussion

SmartGrid Evidence Standards
To start this analysis we need to set a stake in the ground for any digital billing and TOU
control practice which meets proper evidence standards. And further that as part of
practice, all SmartGrid systems (as in Energy, Water, Heat, etc.) must produce a proper set
of evidence as proof of their operations, and logs which provably allow for their
documentation of the delivery of service and the settlement processes.


CPUC already has rules pertaining to computer information (10.3 and 10.4) and these
would also apply to SmartMeters and their operations as well as devices which connected
to the Meter either directly or through the power lines as well.




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State and Federal Standards for Court Admissibility of Evidence
     already exist
Certichron also believes that to make SmartGrid a success that functionally speaking the
trust processes around the TOU Monitoring need to be ones which provide a truly objective
and arms-length evidence model for all TOU/Primary Providers, and the related Consumer
transactions whether they occur over the SmartGrid itself, the Internet, another
telecommunications service interface or other Energy/Utility delivery models including
but not limited to traditional DA, DR or other account relationships. Further, those optional
third-party monitoring services should be available to allow for an independent provider of
Trust to any of the SmartGrid’s transaction process(es) as an Energy Management Service
component or stand-alone offering.


Further that both State and Federal governments already have well tested and easily met
Digital Evidence standards in both their Courts and before their Agencies, and that the
CPUC’s operations are constrained therein.


To facilitate this Certichron believes therefor that it is appropriate to specify that


       “Any and all SmartGrid monitoring processes must also produce court
       admissible evidence of operations which meets the minimum legal standards for
       digital evidence both at the State of California's level and that of the Federal
       Government".

as part of the 12-009 ruling.


The reason is that both State and Federal evidence standards are required since it is
already common practice in California to take bulk power from independent, private and
Federal sources outside of California making the Federal standards apply.


The inclusion of a third party, to generate and officiate those evidentiary grade time stamps
as part of every transaction is another potential key step towards assuring compliance with




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      Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


the state and federal evidentiary standards. It is for that we also seek acknowledgement in
the Motions as well.



Cyber Security – Secure and provable/private record services

First, on the issue of cyber security, the Proposed Decision cites three documents that
National Institute of Standards and Technology (“NIST”) Computer Security Resource
Center1, a service of the NIST Information Technology Laboratory, who in cooperation with
the Department of Homeland Security have prepared that provide Federal guidance on
cyber security issues. However, as the Proposed Decision points out, while these guidelines
provide useful guidance, they alone cannot address all of the potential security
permutations that a deployment presents.


To do that effectively, utilities and their third-party time-service providers will need to
fully meet existing US and California State Evidence Standards as a point of sale control
system opening up a number of control opportunities as well as a new service for CAISO
possibly (i.e. vending machine licenses for each SmartGrid meter operating as an energy
purchase and control station).


We do differ however from AT&T's reasoning about who should be involved in keeping the
providers honest. To quote AT&T’s response:
           “The Grid should be thoroughly reviewed for potential security breaches, but
           utilities and communications providers should use their own professional judgment,
           as informed by the NIST and DHS general guidance, to determine the steps to take to
           ensure security while controlling the costs which consumers ultimately must bear.
           This places cyber security responsibility squarely where it should be – on the utility
           operating the particular aspect of the Smart Grid. Allowing utilities to demonstrate
           reasoned conformance with the NIST and DHS guidelines rather than requiring
           absolute compliance will encourage better and more adaptive cyber security
           practices. And adaptation is what cyber security is all about. Standards are relatively
           static but cyber risks are dynamic.”




11   http://csrc.nist.gov/index.html


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We disagree with AT&T’s view as highlighted above. The risks in allowing the delivery
operator to stand as the trusted-partner is contrary to all objective control practices used
today in all regulated industries. This is no more than the “Trust Me I promise I will do it
right” commentary we heard from Enron and many others over the last two decades.



California’s SmartGrid needs trust capability which exceeds any one
       party’s potential to commit frauds.

Bluntly the system must be better than the people who operate it to protect the Public
Trust it is being rolled out to support.


This applies to Time of Use controls especially since there are legal requirements under US
law for which timescale, in this case NIST(UTC) must be used for legally enforceable time-
service transactions.


Likewise from a trust perspective while the” Operator of the Last Mile” provisioning is one
party who should be tracking the Time Of Use controls they are not an objective
representative of the end-user’s Time of Use Data.


Why? A simple 2 minute ‘time-slip’ for instance in a billing cycle would produce a
misstatement and the associated billing for hundreds of millions of dollars over a year for
most medium sized utilities and that scales for the larger entities here in the State of
California.



Adding a trusted-third party to the SmartGrid’s operations

Traditional Network Service providers have learned that two party transactions are
generally just that. Meaning that the evidence they produce is generally tied to the
testimony of the two parties involved directly making it he-said, she-said in form.




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In the Utility Operations world this takes on new meaning since TOU billing is becoming
key to managing costs and keeping proper use loading consistent. The only way to provably
add trust is to add a trusted third party


Because of this potential and the sheer number of intended frauds from an investment
standpoint in the Energy Sector over the last ten years, there is a serious lack of trust in
Energy Sector executives. When leveraged against the misstatement of client-use in Smart
Meter operations which have in fact occurred, a trusted third party to any of these
operations of the SmartGrid is the only reliable way to create global levels of trust.


Simply put, Time of Use (TOU) service models mandate a provable way to document the
use of the Energy commodity. They also strongly define where customer controls start and
suppliers infrastructure ends.



SmartGrid and the Vision

With regard to the existing and new SmartGrid itself, the few considerations we propose to
make are made in the Proposed Decision, and are made to ensure that the Grid can provide
reliable evidence of its proper operation, and through this to create the transparency
necessary in an open market.


       [p.108] “16. A presentation of a Smart Grid Vision Statement that shows that the
       proposed deployment plan advances a “Smart Electric Market” that is transparent
       and demand responsive, provides pricing information and promotes an open energy
       trade and delivery platform would be consistent with SB 17 policies and initiatives.”

With a fully empowered and transparent grid the End-User should be able to buy their
energy from anyone offering it for sale and contract for the delivery of that energy through
their Last Mile Provider. The enablement of the SmartGrid as a transparent platform for
energy distribution requires a uniform evidence model which meets all the legal
requirements for operations both within and across State borders. Certichron believes that




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the rate design embodied in this description is easily accomplished by the integration of a
proper legal model and trusted third party.




Applicable Security Standards – NIST SP800-52 and 53

The controls which allow for billing and adaptive rate plans to be put in place need to be
provable and secure, and as such meet both NIST SP800-522 and 533 standards for
Information Security as well as the NIST ICS recommendation. Additionally there are a set
of US Critical Infrastructure Controls which DHS has in place which any Utility Service
operated to serve the Public Interest must meet.


With advanced pooling and local/regional energy reservoirs being used to buffer D/A and
other bulk purchases, the smart solution is one which fully implements a set of controls
that comply completely with NIST service requirements including the use of the NIST
timebase as the trust-anchor for all transactions.



CPUC Open Rate Models
We strongly agree that tariffs and pricing impact all forms of supply and demand-side
activities, including direct access (“DA”), demand response (“DR”), energy efficiency (“EE”),
and time of use (“TOU”) systems and as mandated are easily delivered when they are
operated with a trusted third party time-service provider and that evidentiary grade time
and trusted-third party security model will address the control-processes needed to enable
all of the open rates contemplated in the ruling.


Meter Management Solutions exist which allow the use of already deployed accessible
meters as well as more network/communication savvy meters so the ability to deploy safe
and secure meters as well as Internet and existing Last Mile based control systems as in


2   http://csrc.nist.gov/publications/nistpubs/800-52/SP800-52.pdf
3   http://csrc.nist.gov/publications/nistpubs/800-53-Rev2/sp800-53-rev2-final.pdf


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solutions like those proposed by AT&T and other Internet Service Providers make the
potentials of an open marketplace attainable in a much more aggressive timeline that many
would think.


With the Meter as the Bright-Line CPE demarcation point it becomes the key agent for
controlling the timely logging of its activities. Certichron supports commentary from Wal-
Mart and others on the importance of properly demarking customer and supplier
perimeters as well.



Other CPUC Dockets this affects
Certichron also notices that Evidence Standards and in particular time-management in AMI
services are a key component in TOU billing systems and should be afforded the same
consideration in at least two other planning related open rulemaking dockets at the
Commission, namely:


       Order Instituting Rulemaking to Integrate and Refine Procurement Policies and
       Consider Long Term Procurement Plans, R.10-05-006, filed May 6, 2010;
and
       Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider
       Refinements, and Establish Annual Local Procurement Obligations, R.09-10-032,
       filed October 29, 2009.


Certichron believes the same set of services proposed here for 09-12-008 and based on the
availability of real NIST calibrated time services to the meter and AMI infrastructure, that
the Commission is warranted in continuing to meet the milestone deadlines and goals for
providing consumers with access to data adopted in D.09-12-046, with three milestones,


those being:
       the policy objective for the provision of retail and wholesale price information by
       the “end of 2010,” ; and


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       which also provides access to usage data through an agreement with a third party
       by the “end of 2010,”; and
       Access to usage information on a near real-time basis for customers with an
       Advanced Metering Infrastructure (AMI) meter by the “end of 2011.”




Investor Owned Utilities (IOU’s) and Providers each qualifying their operating
     Security Models
Certichron also applauds AT&T’s commentary of
       “IT SHOULD BE MADE CLEAR THAT IN ADDITION TO FOLLOWING THE NATIONAL
       GUIDELINES UTILITIES AND COMMUNICATIONS PROVIDERS MUST ENGAGE IN
       THEIR OWN DETAILED CYBER SECURITY RISK ASSESSMENT.”

In that each open and transparent delivery, accounting and billing control system used in
the SmartGrid must meet the minimum legal standard for trading and delivery of energy in
all rate models. AT&T also notices that the standards are National ones making time a key
federally supplied resource in the TOU operations.


To insure this Certichron proposes a set of additional language to the decision providing
direction about what evidence standards the Grid’s operation will provide and how these
are to be administered to insure compliance with Court Evidence Standards in those
proceedings before PUC’s Administrative Law Judges, California, and Federal Courts that
any participant in the California Smart Grid may come to face.



Breaking up the SmartGrid model – defining the CPE Demarcation point
Much talk has been made on defining responsibility for security in operations based on
which SmartGrid component we are referring to. This has culminated in the creation of the
Bright-Line Concept regarding Customer’s CPE and where the customers infrastructure
begins from the Grid it is interfaced to. Certichron believes that to be truly open that
Customer’s must also be able to contract for third-party independently verified time



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services as a service to ‘keep the Grid Operator honest’ and to insure their rights are
properly protected therein.


Certichron believes that from an evidence perspective this is also important in the
definition of where the “hard-lines in the sand” in the deployment model are drawn. These
controls will effect what the SmartGrid will be and what it evolves into. The analysis and
placement of proper demarcation controls will better define who is responsible and for
what they are responsible for. For instance privacy and information integrity laws clearly
apply to information on the client’s side of the SmartMeter installation and as such that
information will have to be provably protected in the SmartMeter operations model.
Likewise, how all of the key calibration data is delivered to the meter must also be
documented in these operations models.



The first example – The L1 GPS System
As an example of why this first ruling is necessary, the California Public Utilities
Commission and other Electrical/Utility Regulatory Agencies are now approving GPS-based
timing control systems as trusted sources of time for SmartGrid and SmartRate operations
without we believe, documenting the well-known liabilities, ease of spoofing and jamming
potentials which already are happening to users of that equipment, meaning that L1 GPS
itself is questionable as a source of trustable time or location data in any regulated system.


The question this motion seeks to answer is then how can L1 GPS be allowed to act as a
stand-alone source of time, when from a Security Model its use fails both NIST SP800-52
and SP800-53 standards for secure information. And because of this failing whether its use
in the TIME OF USE billing systems also fails to meet the standards of the Public Trust
today set as a basic standard of security in the operation of the SmartGrid, Substation
Automation, ESP, and SCADA control systems.




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Motion to take Notice that L1 GPS fails to meet minimum security as a time
     source
Certichron applauds the Commission actions in developing a measured, systematic
approach to establishing the requirements for Smart Grid deployment plans pursuant to
the mandate of Senate Bill 17 and wants to, through this commentary, formally serve the
commission notice “that there are both technical and US Policy Issues which may prevent
the use of GPS L1 Time Services as a sole source of time for TOU Billing Controls” which
Certichron believes warrant inclusion in any system who’s output is regulated under State
and Federal Law


Commissioner Ryan’s Proposed Decision, when implemented, lays out the framework for
how such plans will be filed and reviewed while taking into account the ongoing work
currently underway on SmartGrid issues nationally. To that end, the Proposed Decision
correctly:
       recognizes the benefit in following national standards and guidelines for
       interoperability
       recognizes the importance of privacy and cyber security issues and their inclusion in
       the Deployment Baseline report and also for developing plans for the provable
       deployment of time in computer networks used to control policy and billing of
       energy services.
       requires consideration of third party communications providers’ networks in the
       deployment strategies
       recognizes through the references to NIST standards the value and credulity that
       NIST certified technology and evidence brings to the operation of the California
       SmartGrid infrastructure


       And finally we believe that while not specifically spelled out, its intent is that it
       recognizes the importance in meeting “Minimum Digital Evidence” standards in the
       acceptance of SmartGrid systems and TOU operations and it is this we wish to
       clarify with this motion.



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Certichron who has worked with US and State Court’s in debunking the myths about the
Security and Reliability of the US L1 GPS Services, and now looks forward to working with
the California Public Utilities Commission (CPUC) on the future phases of this proceeding
and in the roll out of evidence standards and time management solutions for the Smart Grid
to protect the integrity of Time of Use billing and Rate Plan implementation and the all-
important privacy and cyber security interests associated with Smart Grid deployment


To accomplish this Certichron does further move the California Public Utilities Commission
(CPUC) and its Administrative Law Judges to take formal notice of the physical limitations
of limits to the unattended or controlled operation of L1 GPS functionality and many
known security limitations of the L1 GPS System, and as such ban its use “as a sole-source
for time and frequency controls in Energy/Utility SCADA, Delivery and Billing Control
Systems in Utility Operations for the State of California’, and to in doing so to embrace the
same policy the US DoD used to ban the purchase of the same unencrypted L1 GPS
systems in 1998.


       This order was in fact issued based on the Joint Chiefs of Staff’s internal knowledge
       of the flaws and trust issues with the L1 system for any uses which are intended to
       create “enduring proof” by them or which could be used to change any aspect of life
       which could have catastrophic consequences (in a military theater). Certichron
       believes that the Critical Infrastructure of the US and California Power Grids are
       controlled under the same technical needs and as such these concerns become
       critical to the operation of a National Resource like the California Power Grid.


       Because of these design limitations the L1 GPS system without significant trust
       additions is an unacceptable tool for use in deploying time to the SmartGrid itself as
       an instrument or component of a SmartRate Billing model based on the total lack of
       security and ease which with L1 GPS signals and records are spoofed, jammed and
       made unusable.



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It is for these reasons we assert that the Commissioners need to review basic evidence
controls in network systems and how those can be made stronger to protect the consumers
without adding significant costs to the consumers and it is for those reasons that
Certichron submits this motion formally to the CPUC and ALJ Sullivan for review and
action.



Many SmartGrid deployment control systems today use the L1 GPS as a
          sole time source

Today because of how easy it is to deploy a L1 GPS based timing solution, more and more of
them are being used to serve critical infrastructure uses.


The problem is that the parts of the GPS system which are available to the Public and thus
the Power Grid itself are of the unsecured L1 services. The same L1 GPS services the Joint
Chiefs of Staff “banned the use of in 1998 with their order ‘such that only SAASM –
encrypted GPS could be purchased by the military’”. What this means is that no one in their
right mind uses L1 GPS for anything which has to be legally provable.


The issue the CPUC faces here is that vulnerabilities of L1 GPS services are most often not
discussed by those promoting their use to establish time records, leading to decisions to
implement them which in fact do cause problems at a later time.



The L1 GPS will most likely fail a Daubert Hearing or Frye Test as
          reliable evidence

Unfortunately no US Court has allowed any technical review of the GPS system so there has
never been a formal review of the system before a Judge but what they would find is that
the GPS L1 facilities can be spoofed so easily that it makes no sense to use them for
anything that is based on provable trust.



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But it should be noted that based on all of the well-known holes and failings of the L1
system that under a Daubert Hearing or through the simple application of a Frye Test the
L1 GPS system will most likely formally fail to meet even a basic semblance of an
evidentiary standard of operations from a forensic perspective. The issues are the design
of the passive architecture with no “feedback loops” to properly document anything about
the transmission, or the reception of and proper processing of those TIME MESSAGES from
the L1 GPS satellites.


Bluntly there is no prove, or obtain reliable evidence in any L1 GPS system without an
external management practice to continually compare those station’s in a provable manner
to a known National Timing Standard in a provable manner. This is the curse of the
tremendously useful L1 infrastructure in that it was built to be used anonymously and with
limited authentication if any.


The nature of the security problem is serious enough that many divisions of the Executive
Branch of the US Government outside of the DoJ have active GPS Risk Assessment plans in
place including some security practitioners like the Los Alamos Laboratories GPS Risk
Assessment Team.



Staggering amount of Scientific and Government Evidence supporting
       that “this is a true liability”

There is also considerable official and industry/scientific peer review to support the notion
that the use of GPS alone for anything critical without continuous Human Oversight is
foolish at best.


This commentary looks at the need to create and provide a reliable evidence practice for
controlling energy and utility delivery systems and comes to the conclusion based on how
networking models work, that a two-party network transaction will ultimately only



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provide a he-said, she-said proof model, and that what is needed is a real trusted third
party to manage the time service aspect of Energy Management Systems and their
activities.



Joint Chiefs of Staff ban the use of Unencrypted L1 GPS Services

Because the L1 GPS system doesn’t provide evidence of its proper operation, relying on it
in any systems “requiring provable evidence of time or location” cannot be done without
continuous human oversight or some other out of band method


In fact, the ruling from the US Joint Chiefs of Staff banning the use of Unencrypted GPS for
any military operations came in mid-1998 but was delayed in its enforcement until October
1st 2006 when all Military purchases of any GPS systems must have the classified SAASM
additions. SAASM additions are available to the public or utilities, and virtually Security
Experts in the Industry know and have known for years how spoofable the L1 GPS system
is.



GPS is passive in its architecture – and operates at a very low power level

As to the limited trust-model the L1 GPS system provides, we need to take into account
how GPS works. The GPS system is a fleet or ‘flight’ or constellation of GPS satellites.


The GPS system is a passive navigation beacon system which transmits a set of well-known
messages called Ephemeris Data to anyone who will listen for it. Once heard it is up to the
listener to decode the information and through some simple math determine a relative
estimated position of the device comparing those multiple signals to one-another.


Because GPS is a passive broadcast-only tool-service it can only be a source and not proof
of anything because it has no knowledge of or information about the listening client’s.




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Generating Proof – Why GPS needs an extra mitigating control

Proof is attained by being able to demonstrate to California State and US Evidence
Standards that something actually happened in the real world at some specific time and
GPS is a trust-based service meaning while it may in fact work as advertised it is not
provable after the fact, making it worthless for evidence.


This means that some other process needs to be used to verify the proper reception of the
time service and its inclusion in the operating logs. Without this other proof GPS is no
better than human Hear-Say evidence, and since it has no proof for it whatsoever, it’s
mechanically faulty as evidence in a court of law.



Spoofing and Jamming L1 GPS is so simple…

As to the L1 GPS systems spoofability (i.e. how easily it is compromised), or for that matter
how easily it is rendered inoperable and jammed by something as simple as a $20 dollar TV
Amplifier from Radio Shack also shows how little diligence was done on the creation of a
legally provable evidence model here.


       http://www.uscg.mil/hq/cg3/cg3pcx/publications/alcoast/alcoast-298-03.asp
       http://www.navcen.uscg.gov/cgsic/meetings/EISubcommittee/2005_presentations
       /06%20Vulner%20PRA.ppt


To help those reading this understand how dangerous relying on L1 GPS is, this try the
following GOOGLE SEARCHES


       http://www.google.com/#hl=en&source=hp&q=Spoofing+GPS
       http://www.google.com/#hl=en&source=hp&q=Spoofing+GPS+VAT
       http://www.homelandsecurity.org/bulletin/Dual%20Benefit/warner_gps_spoofing.
       html




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GPS is not a legal source of time in the US

Unfortunately there is another issue in the reliance on the L1 GPS System as a part of the
SmartGrid without external monitoring and that is that it is not a legal source of time in the
US per 15 USC §271 and §272 and no one, not the US Department of Commerce spokesman,
the NavStar JPO’s spokespeople or anyone connected with the operation of the US GPS
system can change that under US Law. In the United States, only the NIST(UTC) time
service is the legal time of the US Government.


Only the formal amendment of the two key sections of 15 USC, Sections §271 and §272 as
well as probably repealing 15 USC §260 could possibly fix that, and that as a by-product
this would invalidate about 134 Metrological Mutual Recognition Agreements (like the
NORAMET Agreement for instance) and any number of Trade Agreements between the US
and other nations, so it is very unlikely to happen.


       http://www.law.cornell.edu/uscode/uscode15/usc_sec_15_00000260----000-.html
       http://www.law.cornell.edu/uscode/uscode15/usc_sec_15_00000271----000-.html
       http://www.law.cornell.edu/uscode/uscode15/usc_sec_15_00000271----000-.html

We talked about the NORAMET agreement above and it is important since it specifies an
official agreement between the Nations of North America regarding the official
interoperable source of time (the following link will produce a scanned copy of that
agreement).


       http://sup1.certichron.com/wp-content/uploads/2010/06/NORAMET-
       Agreement.jpg


As to how NIST(UTC) and the GPS system relate, they don’t. The source of time for the US
GPS system is the USNO’s Alternate Master Clock system making the US Navy itself the
source of time for the GPS network. The USNO operates the AMC through the US Air Forces



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operations at Schriever Air Force Base in Colorado Springs where the Navy’s Alternate
Master Clock (the source of the master GPS time signal) is kept.


       http://en.wikipedia.org/wiki/United_States_Naval_Observatory
       http://tycho.usno.navy.mil/twstt_amc.html

And while the GPS clock may be technically accurate, it’s neither provable from L1 Users
standpoints or the legal or recognized source of time in the US.


   3. Conclusion
In closing this we applaud the Commissioner’s work in this ruling and believe it is in the
best interest to keep the decisions time-lines intact since the technology to address the
control issues and quality of evidence being produced at all levels of the SmartGrid system
exists today and is in fact ready for use in California. The following two examples clearly
document the issues with GPS L1 services. CPUC rules 10.3 and 10.4 actually already
require this but in the case of the L1 GPS systems use these efforts were omitted for some
reason. The CPUC rules are supplied in the appendices for quick-reference here as well.


In all of these instances, because of the importance of the matter, Certichron moves the
CPUC for both the proposed evidence standard rule and under it a finding of fact herein
about L1 GPS’s undisclosed liabilities.


Certichron believes there is an answer to this, which also dove-tails with AT&T’s
commentary about the third parties to the Energy Management Practice, in that they can
provide this trust to insure that all parties are operating properly and all of the delivery
technology is also operating as it should.


Certichron like AT&T is one of these entities and believes that the answer to this complex
issue is to buffer the two parties by having a trusted third party (TTP) involved in the time
management process to provide proper evidence of the time-of-day control practice.




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Certichron looks forward to participating with these third party providers and the Energy
Service Providers/Grid Operators to make NIST(UTC) the preferred time on the Grid.


To that end, and before the Administrative Law Judges of the Commission we move as
follows:



Motion 1: Certichron’s Motion for an issuance of a Rule regarding that
      “SmartGrid systems must produce evidence meeting the defined
      standards for court admissibility”
Based on these numerous issues, Certichron formally moves the CPUC to issue specific
guidance that “All SmartGrid” component systems will also comply with CPUC Rules 10.3
and 10.4 (see Appendices) and their vendor’s and operator’s must produce evidence of
their operation which meets the California State and Federal Rules of evidence and
precedents such as LORRAINE (see Appendices).


And to also enforce the Digital Content mandates under the already recognized NIST
SP800-52 and 53 standards, or per other CPUC approved Security Standards including
FISMA (Federal Information Security Management Act4) and FISCAM (GAO Federal
Information Systems Computer Auditing Manual – aka “the Yellow Book”5), or those put in
place by FINRA OATS6 Rule #7430 and the related controls around the FINRA Order Audit
Trail System (OATS) which was extended in the last month to cover all Securities and
Commodities Trading in the US after the 1000 point NYSE Dive as a new and key part of the
set of trading controls to prevent mishaps in the fabric of the market. The SmartGrid
ultimately suffers the same potential and based on how TOU is to work to a similar scope-
of-damage potential. As such the application of OATS ideas and standards to the Security
Model for the operation of SmartGrid resources in California is a good idea7.


4 http://csrc.nist.gov/groups/SMA/fisma/index.html
5 http://www.gao.gov/special.pubs/ai12.19.6.pdf
6 http://www.finra.org/Industry/Compliance/MarketTransparency/OATS/

7For the commission’s and others reference, the OATS is a very well tested control service
that NASDAQ designed system for tracking securities and is also now used in commodity


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Motion 2: Certichron’s Motion for an Order mandating a Provable level of
     Integrity in Digital SmartMeter’s Evidence Capture models
We at Certichron further move that the CPUC take formal notice on these described and
documented liabilities and issue a directive therein as requested above in the opening
commentary. We as such move the commission to add the following additions to the
operating requirements for SmartMeters licensed in the State of California, so that they
properly meet the basic time-evidence functionality necessary to properly implement
“Time of Use” billing models.


       “Any and all electric or utility meters deployed to measure the customer’s
       consumption or transfer of energy or utility resource into the public use or through
       the SmartGrid itself must meet both State of California and Federal Evidence
       Standards for their operation, but also must comply with all metrological
       requirements for the use of the appropriate source of time and proof models to
       properly document its use.”

On Open Transparency and Reliance on L1 GPS for time services
    alone for SmartGrid
Since with L1 GPS systems there is no way to functionally prove the accuracy of the time or
when for that matter those records were actually placed into those SmartMeters, Area
Collector Radios and other AMR/AMI service components, until such time as a better
solution, one which can provably prove the time service at the meter, substation or switch-
house/generation source, no time-based arguments will be anything more than two party



transactions of all types. OATS or the control aspects it represent have specific value for
consideration here because of the impending roll out of both Internet/Grid connected systems
which will in the very short term provide for the purchase of bulk power online and to actually
participate as an individual in energy future,. The reasoning is that the SmartGrid receipt of
power consummates an action which was started on the Internet under either a State of
Federal Regulatory control and that Energy is in this context identical to Gold Bullion which
is purchased as a commodity on the exchange, in that it can be ‘received’ and possessed, or
in the case of Energy, used, consumed for the purpose of work, meaning it completes the
FINRA regulated transaction.


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unsubstantiated arguments and as such there is no possible way to resolve them since the
evidence8 of operation is missing.



Summary
For those reasons, we propose that these rulings are necessary to protect the consumer’s
and their resources from unintentional and intentional abuse regarding the billing that is
produced through the SmartGrid System and to streamline the dispute resolution process
by pre-qualifying the evidence created in the SmartGrid as part of its operations to meet all
State and Federal Evidence Standards.


Todd Glassey CISM CIFI
Chief Scientist, Certichron Inc.




8   http://www.informationweek.com/news/personal_tech/gps/showArticle.jhtml?articleID=217201050


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Appendices – GPS jamming and Spoofing Technologies
The following GPS Jamming/Spoofing Information is all available online through Google
and many other sources.


GPS Jammers are commercially available from China and other sources
                                   Today L1, L2, L5 Bands Car-based GPS Jammers are
                                   available off the shelf from China and other sources
                                   around the globe. These Jammer/Spoofer Simulator’s
                                   used to be very expensive but this mobile four-
                                   transmitter unit is only a few hundred dollars making
                                   GPS spoofing commercially within the grasp of anyone on
                                   the street with a need to ‘modify’ their TOU billing
                                   services or rates.


GPS Jamming Plans are also commonplace today and that means that GPS L1 by itself is
untrustable for any critical applications.

Sample GPS Jammer Schematic – Build your own for under $50 USD
The following GPS Jammer design is a tested device which as it turns out doesn’t take a
bachelors in engineering to whip up, in fact one of my friend’s 13YO daughter put one of
these up on a “protoboard” in 20 minutes after pulling the parts.

                                                                 Jan 29, 2007 - Today we are
                                                                 featuring an article from
                                                                 Phrack – an online hacker
                                                                 magazine. What we have is
                                                                 a do-it-yourself GPS
                                                                 jammer that can have a
                                                                 range of upto several
                                                                 hundred feet. Keep in mind
                                                                 this is not an easy hack – a
                                                                 bachelors in electrical
                                                                 engineering seems like a
                                                                 prerequisite.




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The GPS band pass filter is a 2-pole Toko 4DFA-1575B-12 ceramic dielectric filter from
Digi-Key[4], part number TKS2609CT-ND. This part is optional, but helps clean up the RF
spectrum before further amplification. The filter’s insertion loss is around 2 dB.

The final RF amplifier is a WJ Communications AH102. It provides another 13 dB of gain,
with a higher P1dB compression point of around +27 dBm (500 mW). The AH102 draws
the most current of any part, and is not really necessary if you’re aiming for a low range,
low current, battery operated device.

This hack is designed to be a low cost one, only using components you can easily find at a
trip to Radio Shack. It targets the Global Positioning System (GPS/NAVSTAR) L1 frequency
of 1575.42 MHz. Also keep in mind this device will not work against the Russian GLONASS
or European Galileo




The above post shows a low cost Jammer type device.

A Spoofer like the RaceLogic9 LabSat GPS Simulator which allows anyone to create a set of
ephemeris messages (like the satellites do) and to replay those messages from the
simulator to emulate and test proper operation of the Ground Segment Device – that would
be the GPS Receiver. With A Simulator like the one in the image below a complete set of six
                                                         GPS signals can be simultaneously
                                                         replayed to make a GPS receiver ‘say
                                                         anything the party operating the
                                                         simulator wants it to’.




The next two posts continue to document the total global realization that as a source of
evidence, GPS systems are iffy at best. Notice the commentary in the YELLOW
HIGHLIGHTED text. These articles also both quote David Last, the ex-president of the Royal
Institute of Navigation in the UK as one of the preeminent experts on the subject of GPS and
its security.




9   http://www.labsat.co.uk/


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Likewise there is also language from the Argonne National Laboratory’s GPS Vulnerability
Assessment Team supporting the idea and fact that GPS is very powerful for tasks with
100% human oversight, but as a source of unattended ‘trust’ they are less than what is
needed in a SmartGrid application without mitigation and some Trusted Third Party or the
like to verify their proper operations.

We extend their security concerns with the idea that any component in the Public Service
as Critical Infrastructure must by that definition meet the legal requirements of the Courts
who are tasked with resolving any matters concerning those entities and the public
whether commercial or personal in nature.




Hacking GPS and Satellite Navigation, the Potential Criminal Payoffs
The next commentary pertains to the criminal use of time or GPS provided time as a
weapon. In the context of the SmartGrid the simple two minute billing error for the
operations of the grid could produce hundreds of millions in wrongly invoiced service
across the State of California and as such this is an important factor in regulating the
California SmartGrid’s operations.



                                     GPS vulnerable to hacker attacks - By
                                     Jason Palmer, Source: BBC News

                                     Given the growing dependence on location based
                                     services and GPS systems, it is clear that attacks on these
                                     core technologies will increase in the future. As noted in
                                     the article below, many companies, especially those with
                                     expensive cargo, are gps-tagging their vehicles in order
                                     to be able to track them. Yet these weak signals are
                                     subject to blocking and even spoofing in furtherance of
                                     criminal activity.

                                    As noted elsewhere on Future Crimes, location-based
                                    services will explode in popularity in the coming years.
Their primary feature set, is also their Achilles-heel, that is the dependence on and
provision of accurate location data. The article below does an excellent job highlighting


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how altering or jamming location based information services might support transnational
criminal activities.


Technology that depends on satellite-navigation signals is increasingly threatened by
attack from widely available equipment, experts say.

While “jamming” sat-nav equipment with noise signals is on the rise, more sophisticated
methods allow hackers to program what receivers display.

At risk are not only sat-nav users, but also critical national infrastructure.

A UK meeting outlining the risks was held at the National Physical Laboratory in
Teddington on Tuesday.

       “GPS gives us transportation, distribution industry, ‘just-in-time’ manufacturing,
       emergency services operations – even mining, road building and farming, all these
       and a zillion more,” David Last, a consultant engineer and former president of the
       Royal Institute of Navigation, told the conference.

       “But what few people outside this community recognise is the high-precision timing
       that GPS provides to keep our telephone networks, the internet, banking
       transactions and even our power grid online.”

       “ You can consider GPS a little like computers before the first virus – if I had
       stood here before then and cried about the risks, you would’ve asked ‘why
       would anyone bother?’ ” - David Last, former president of the Royal Institute of
       Navigation


       Professor Last recalled the New Year’s Day failure of a single satellite in 2004 and
       how it wreaked havoc with sat-nav readings. “Satellite failures, though dramatic, are
       not the main problem,” he said. “The Achilles heel of GPS is the extremely weak
       signals that reach the receiver.” Each satellite in a sat-nav constellation is putting
       out less power than a car headlight, illuminating more than a third of the Earth’s
       surface at a distance of about 25,000 km.

What that means, and what has brought this group of policy-makers, academics and
industry figures together, is that the signals can be easily swamped by equipment back on
Earth.

Criminal intent

This can be done unintentionally by, for example, pirate television stations, or with a
purpose in mind. Military systems have been doing this “jamming” – flooding an area with a



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signal at the GPS frequency – for years in a bid to frustrate enemy navigation systems. But
today small jamming devices are increasingly available on the internet.

       Low-power, hand-held versions can run for hours on a battery and confuse sat-nav
       receivers tens of kilometres away.
       Higher-power versions can do far worse, and at both GPS and mobile phone
       frequencies.

What is more, receivers can be “spoofed” – not simply blinded by a strong, noisy signal, but
fooled into thinking their location or the time is different because of fraudulent broadcast
GPS signals.

“You can now buy a low-cost simulator and link it to Google Earth, put on a route and it will
simulate that route to the timing that you specify,” said Professor Last (Professor Last is the
head of the Royal Navigation Society). A GPS receiver overcome by it will behave as if
you’re travelling along that route.”

The approach still costs in the thousands and is the preserve of what Professor Last calls
the “real techies”, but he guessed that the tools could be in the hands of criminals within a
year or two.

One obvious reason to do the jamming or spoofing is that high-value cargo is tracked with
GPS, as are armoured cars and many rental cars, so that confusing the tracking signal could
spell a successful heist.

Sat-nav-based pricing for toll roads and road usage charges could be spoofed, and a
company’s employees may even use the devices to block the tracking devices imposed on
company cars.

But jamming and spoofing, Professor Last said, were irresistible to the hacker type who did
it for fun.

“You can consider GPS a little like computers before the first virus – if I had stood here
before then and cried about the risks, you would’ve asked ‘why would anyone bother?’.

“It’s the same market as the hackers.”

But the hackers’ fun poses a particular danger to ships, which have systems that
increasingly use sat-nav directly but also feed GPS signals into other equipment.

Some at the conference argued that with the growing maritime use of sat-nav, crews were
less able to revert to classic methods of map-reading and “dead reckoning”.

Alan Grant of the General Lighthouse Authorities carried out an experiment in 2008 to
assess the degree to which ships would be affected by a jamming signal. “The level of



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disruption depends on the ship – the make and model of the kit, how it’s been integrated,
and down to the strength of the jamming signal,” he said.

But he suggested the more dangerous case is that of a jamming signal causing only
small errors that would not so obviously give themselves up as false information.
The immediate solution to the problem is not clear, since the existing US GPS and
Russian Glonas systems, and the forthcoming European sat-nav effort Galileo, are
equally susceptible.

Some at the conference suggested the relative security of the eLoran ground-based system
that is already in place, but which existing consumer devices do not pick up.

There is no reason to believe, however, that widespread adoption of eLoran or any other
standard would preclude eventual jamming efforts to thwart it.

“Navigation is no longer about how to measure where you are accurately – that’s easy,”
Professor Last said. “Now it’s all about how to do so reliably, safely and robustly.”



The implications to the CPUC of the highlighted section above are pretty ominous since it
seems as though the dangers of relying on GPS L1 services have either been downplayed to
allow their adoption or misstated as to the dangers of using them as a sole source of
evidence for TOU billing controls.




Car thieves using GPS 'jammers'
In the next supporting publication we cite the use of a mobile jamming system for
‘hijacking cargo on the open road’. This same potential was documented in the Argonne
National Laboratories effort with Los Alamos in the ‘hijacking of a gasoline tanker on the
open highway’ to demonstrate the liabilities of GPS tracking systems.


The hijacking prototype all too quickly became ‘how it’s done’ and is now part of a set of
bad-guy tools commonly used in the hijacking of motor and cargo freight. The point here is
that GPS is not reliable and can be manipulated easily by a person with limited technical
training, all it takes is Google and an interest in asking the “how do I” question.




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'Jammers' overwhelm anti-theft devices on cars and lorries – and later versions could be
used to disrupt air traffic

   Charles Arthur guardian.co.uk, Monday 22 February 2010 18.29 GMT

Criminal gangs have begun using GPS "jammers" imported from China to help them steal
expensive cars and lorries carrying valuable loads – and there are fears that terrorists
could use more powerful versions to disrupt air traffic, a conference in London will hear on
Tuesday.

The "jammers" put out radio signals at the same frequency at the Global Positioning System
(GPS) satellites, overwhelming the timing signal that in-car devices use to plot their
position. That means a tracker device built into a lorry with a valuable load, or a car with an
anti-theft GPS device which should report its position if stolen, cannot distinguish the
correct GPS signal.

"It disappears from the radar," said Professor David Last, of the University of Wales at
Bangor, who has been a police expert witness in a number of cases over the past 18 months
in which GPS jammers have been seized.

Some German drivers are also believed to use such jammers to try to evade GPS-based road
charging, which was introduced for trucks in 2005. There have also been robberies in
Russia where such jammers have been used against both GPS systems and mobile phones
on lorries to prevent the driver from contacting the authorities.

In Germany, as in the UK, it is illegal to sell or use such jammers – although it appears to be
legal to import or own them.

Satnav devices rely on being able to "see" at least four of the 30 satellites orbiting about
20,200km (12,550 miles) above the earth: by correlating the very precise timing and
identification signals they transmit, a ground-based device can calculate its own location to
within about 1 metre. However, the jamming devices do not have to put out a strong signal
to disrupt GPS reception.

"The problem is that the signal from the satellites is extremely weak – it's the equivalent of
picking up the light output of a 25-watt bulb on the satellite," said Bob Cockshott, another
conference speaker who heads the location and timing program for the Technology
Strategy Board, funded by the Department of Business, Innovation and Skills.

"That means you only need a jammer with an output of about 2 watts to swamp any signal
from the GPS satellites over an area of a few metres." Such a device would be billions of
times more powerful than the GPS signal at ground level.




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Cockshott says that such more powerful jammers could have multiple uses for criminal
gangs. "They would work over tens of kilometres, so drugs gangs might use them to disrupt
navigation in the Thames estuary if they were taking a delivery and didn't want rivals to be
able to trace them."

Such systems have been found in the hands of criminals arrested by police over the past 18
months, said Cockshott. The jammers could be built by a competent electronics expert,
though the gangs appear to prefer to import them from Chinese makers in Shenzhen.

"We need to make users of GPS aware of the threat," said Cockshott. "They need to use a
complementary technology so that their systems work without GPS." Systems that
triangulate on mobile phone masts, and another which uses a ground-based network,
called eLoran, can operate even when GPS signals fail, he said.

Professor Last said that the use of these systems by criminals and terrorists had been
anticipated since 2002, when the US government produced a report pointing out that
disruption to GPS could cause "severe safety and economic damage to the US".

Charles Curry, the managing director of Chronos Technology, who also heads a consortium
which is building a GPS-jamming detection system with a £2.2m UK government grant, said
that the biggest fear was that a powerful GPS jammer with an output of 20W or more might
be used by terrorists near an airport.

"If you lost GPS capability on planes or other things that rely on accurate timing, such as the
emergency networks or power stations, then if they don't build in the ability to mitigate
against such attacks there could be very serious consequences." The detection system is
now in its prototype stages and would be used at airports, harbours and other locations
which rely on the nanosecond accuracy of GPS outputs.




Jamming of GPS signals threatens vital services
Even the London Financial Times is commenting on how unreliable and easily manipulated
GPS and especially the Civilian use of the L1 GPS service are.

By Peter Whitehead, Digital Business editor
Published: February 23 2010 16:58 | Last updated: February 23 2010 16:58

Critical infrastructure, including air traffic communications, electricity transmission,
telecoms networks and emergency services are all under threat from the increasing
availability of “GPS jammers”, technology experts are warning.




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“A portable jammer in a tall building could cover most of London and aircraft approaching
its airports,” said Professor David Last, a past president of the Royal Institute of Navigation
and now a GPS consultant.

Global Positioning System signals, which are extremely delicate, are now relied upon by
vital sectors, including transport, just-in-time manufacturing and farming.

Prof Last told a symposium, organised by the Digital Systems Knowledge Transfer
Network, that by using GPS a single person could today control a huge vessel sailing in
crowded shipping lanes at 25 knots.

But as reliance on GPS for such tasks increases, traditional back-up systems are falling into
infrequent use and traditional navigational skills are declining, leaving organisations
vulnerable to interference with GPS signals.

The dangers can be unintentional, caused by solar flares or accidents, or intentional, with a
fast-growing criminal element.

“The strength of a GPS signal is about as strong as viewing a 25W light bulb from a satellite
10,000 miles away,” said Bob Cockshott, a director of the Digital Systems KTN. “It’s no
surprise then that GPS signals are vulnerable to natural and, increasingly, criminal
interruptions.”

Jamming devices that can disrupt GPS signals are sold on the internet for less than £100.
Prof Last said they could be used by thieves to block transmissions from stolen vehicles
protected by GPS tracking systems, rendering them “invisible”. Crooks might even transmit
a false location using a “GPS spoofing” device.

He said he had also heard of disgruntled employees buying jammers to defeat tracking
systems installed in their cars by employers.

“These devices are selling; terrorists have been arrested with them,“ he told the
symposium. “GPS now is like computers before viruses. But there are no big security
companies working to protect GPS.”

Alan Grant, a radio-navigation expert with the General Lighthouse Authorities, gave an
example of how a blocked GPS signal could produce dramatic results: in a jamming
experiment off the coast of north-east England, instruments monitoring ships’ positions
showed them sailing over land at speeds of thousands of knots.

Dr Grant said such obvious deviations were not the problem: “It’s the small deviations that
pose the biggest risk.”




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The effect on personnel was equally surprising: “The ship’s crew knew they were taking
part in a trial and so were expecting things to go wrong, yet their first instinct was to keep
checking the GPS. They were far less familiar with alternative systems.”

GPS vulnerability is being investigated by the Gaardian project that brings together
industry and academia. Charles Curry, managing director of Chronos Technology, is leading
the investigation consortium and he believes back-up systems are vital.

“Our project creates a network of sensors deployed at sites in the vicinity of applications
that rely on the GPS signal. We are then able to monitor any change in the signal due to
natural or criminal activity,” he said.

The Royal Institute of Navigation stresses the importance of developing a ground-based
back-up to global navigation satellite systems (GNSS): “There is a necessity for robust,
terrestrial based systems to provide a concurrent, independent source of position and time
information to ensure navigational safety and environmental protection.”

Copyright The Financial Times Limited 2010




USCG: Moss Landing California “Jamming based GPS-ouatage”
In Moss Landing California, across Highway 1 from the Moss Landing PG&E Power Plant an
unplanned event demonstrated why Civilian reliance on the L1 GPS system was dangerous
in areas of Critical Infrastructure.


The incident was tied to a Radio Shack $19 Television Amplifier Module which effectively
took all GPS services out across not only Moss Landing itself but also the adjacent towns of
Marina and parts of the Monterey Harbor as well. An area with an estimated radius of
1.62Km was functionally GPS-dead for a month. That meant for navigation that all service
was RADAR ONLY.


Regarding a SmartGrid implication, this same event would have taken down not only the
TOU operations for Moss Landing and the adjacent areas but also for the power plant’s
operations as well.




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GPS RECEIVER INTERFERENCE FROM ACTIVE TELEVISION ANTENNAS
ALCOAST 298/03

P 231400Z JUN 03 ZUI ASN-A00174000057
FM COMDT COGARD WASHINGTON DC//G-O//
TO ALCOAST
BT
UNCLAS //N16570//
ALCOAST 298/03
COMDTNOTE 16570

SUBJ: GPS RECEIVER INTERFERENCE FROM ACTIVE TELEVISION ANTENNAS

A. USCG G-MOA SAFETY ALERT, DATED 15 NOV 2002.
B. C2CEN SMEF ADVISORY NAVSENS-02-002, DTG 241602Z DEC 02.

1. THIS ALCOAST AFFECTS ALL UNITS WHERE GPS RECEIVERS AND MARINE TELEVISION ANTENNAS ARE
INSTALLED.

2. THE PURPOSE OF THIS ADVISORY IS TO NOTIFY FIELD UNITS OF A POSSIBLE INTERFERENCE PROBLEM
WITH MARINE GPS RECEIVERS ARISING FROM THE OPERATION OF VARIOUS MODELS OF ACTIVE
(POWERED) VHF/UHF MARINE TELEVISION ANTENNAS. THIS PROBLEM IS DESCRIBED IN A SAFETY ALERT
(REF A) RELEASED BY THE CG OFFICE OF INVESTIGATIONS AND ANALYSIS (G-MOA).

3. THE COMPLETE TEXT OF THE ALERT IS POSTED ON COMDT G-M WEBSITE AT:
HTTP://WWW.USCG.MIL/HQ/G-M/MOA/DOCS/11-02.HTM

4. THE TEXT OF THE SAFETY ALERT IS AS FOLLOWS:

SAFETY ALERT-TELEVISION ANTENNAE INTERFERENCE WITH GPS

NOVEMBER 15, 2002 WASHINGTON, DC.

IT HAS COME TO THE ATTENTION OF THE U.S. COAST GUARD AND FEDERAL COMMUNICATIONS
COMMISSION (FCC) THAT CERTAIN CONSUMER ELECTRONICS-GRADE ACTIVE VHF/UHF MARINE
TELEVISION ANTENNAS ARE CAUSING OPERATIONAL DEGRADATION IN THE PERFORMANCE OF GLOBAL
POSITIONING SYSTEM (GPS) RECEIVERS.

THIS INTERFERENCE MAY BE REALIZED AS A DISPLAY OF INACCURATE POSITION INFORMATION OR A
COMPLETE LOSS OF GPS RECEIVER ACQUISITION AND TRACKING ABILITY. THE INTERFERENCE IS NOT
LIMITED TO THE GPS EQUIPMENT ONBOARD THE VESSEL WITH THE INSTALLED ACTIVE MARINE
TELEVISION ANTENNAE. THERE HAVE BEEN REPORTS OF INTERFERENCE OCCURRING ON OTHER VESSELS
AND INSTALLATIONS OPERATING UP TO 2000 FEET AWAY FROM VESSELS USING SUCH ANTENNAS.



June 15, 2010                            34 | P a g e
   Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


IN ONE PARTICULAR CASE, THE INTERFERENCE CAUSED THE POSITION OF THE VESSEL AS DISPLAYED ON
THE ELECTRONIC CHART TO MOVE ERRATICALLY AND DRAMATICALLY OFTEN ACROSS LARGE EXPANSES
OF LAND. AS CAN BE EXPECTED, VARIOUS DATA DISPLAYS INDICATED ERRONEOUS INFORMATION SUCH
AS EXCESSIVE SPEEDS. IN THESE INSTANCES THE PROBLEM WOULD OCCASIONALLY CORRECT ITSELF
WHILE AT OTHER TIMES REQUIRED RESETTING THE SYSTEM. TO THE VESSELS CREW THESE
ANNOYANCES WERE FRUSTRATING AND CAUSED CONCERNS THAT PERHAPS LESS OBVIOUS
INACCURACIES WERE OCCURRING. ULTIMATELY THIS AFFECTED THEIR CONFIDENCE IN THE
PERFORMANCE OF THE GPS AND ELECTRONIC CHART DISPLAY AND INFORMATION SYSTEM.

IF YOU ARE EXPERIENCING RECURRING OUTAGES OR DEGRADATION OF YOUR GPS RECEIVER OPERATION
YOU SHOULD PERFORM AN ON-OFF TEST OF YOUR TV ANTENNA. IF TURNING OFF THE POWER TO THE
ANTENNA RESULTS IN IMPROVEMENT IN THE GPS RECEIVER PERFORMANCE, THE ANTENNA MAY BE THE
SOURCE OF INTERFERENCE IN THE GPS BAND. IN THAT CASE, YOU SHOULD CONTACT THE
MANUFACTURER OF THE ANTENNA AND IDENTIFY THE SYMPTOMS. IF THE TEST IS NOT POSITIVE AND
THE GPS INTERFERENCE PERSISTS, CONTACT THE WATCHSTANDER AT THE COAST GUARD NAVIGATION
INFORMATION SERVICE AT NISWS(AT)NAVCEN.USCG.MIL / 703.313.5900.

5. ANTENNA MODELS IDENTIFIED DURING INVESTIGATIONS OF GPS INTERFERENCE:

A. TDP (TANDY DISTRIBUTION PRODUCTS) ELECTRONICS - MINI STATE ELECTRONIC AMPLIFIED UHF/VHF
TV ANTENNA - MODELS 5MS740, 5MS750, 5MS921.

B. RADIO SHACK CORPORATION - LONG RANGE AMPLIFIED OMNI DIRECTIONAL TV ANTENNA - MODEL 15-
1624, MANUFACTURED BETWEEN JAN 2000 - APR 2002,
HTTP://SUPPORT.RADIOSHACK.COM/SUPPORT_VIDEO/DOC68/68779.HTM

C. SHAKESPEARE CORP - SEAWATCH 2040/CODE DATE 02A00, 2050/CODE DATE 03A00 (CODE DATES ARE
FOUND ON THE ANTENNA POWER SUPPLY), http://WWW.SHAKESPEARE-
MARINE.COM/ANTENNAS/TV/SAFETYALERT-TVANTENNAS.HTM

6. QUESTIONS CONCERNING THIS ALCOAST SHOULD BE DIRECTED TO THE NAVIGATION CENTERS NIS
WATCHSTANDER 703.313.5900, E-MAIL: NISWS(AT)NAVCEN.USCG.MIL OR AT WWW.NAVCEN.USCG.GOV

7. INTERNET RELEASE AUTHORIZED.

8. RELEASED BY RADM DAVID S. BELZ, ASSISTANT COMMANDANT FOR OPERATIONS.

BT
NNN



Appendices – US Evidence Rules and Spoliation of Data/Evidence.

In regard to the US Rules of Evidence, there are new standards set in the US District Court
for how evidence is evaluated in a digital context and as to whether it is admissible therein.
Under the Lorraine v Markel America Insurance Company ruling from Judge Paul W.
Grimm of May 4th 2007.




June 15, 2010                            35 | P a g e
   Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


Admissibility of ESI into Evidence: Lorraine v. Markel
Oct 22nd, 2008 | By admin | Category: Cases

This is the leading case regarding how to admit electronically stored information (ESI) into
evidence. To admit ESI into evidence, certain rules of evidence must be followed. These rules
were recently explained by Chief United States Magistrate Judge Grimm in the case of Lorraine
v. Markel Am. Ins. Co., 241 F.R.D. 534 (D. Md. May 2007).

These rules are important because they can be easily ignored by e-discovery attorneys who are
unaware of the challenges involved with ESI admissibility. Judge Grimm explains:

Very little has been written, however, about what is required to insure that ESI obtained during
discovery is admissible into evidence at trial, or whether it constitutes “such facts as would be
admissible in evidence” for use in summary judgment practice. FED.R.CIV.P. 56(e). This is
unfortunate, because considering the significant costs associated with discovery of ESI, it makes
little sense to go to all the bother and expense to get electronic information only to have it
excluded from evidence or rejected from consideration during summary judgment because the
proponent cannot lay a sufficient foundation to get it admitted. The process is complicated by the
fact that ESI comes in multiple evidentiary “flavors,” including e-mail, website ESI, internet
postings, digital photographs, and computer-generated documents and data files.

See Lorraine, 241 F.R.D. at 537-38.

In Lorraine, the court summarized the process for admitting ESI under the Federal Rules of
Evidence:

Whether ESI is admissible into evidence is determined by a collection of evidence rules that
present themselves like a series of hurdles to be cleared by the proponent of the evidence. Failure
to clear any of these evidentiary hurdles means that the evidence will not be admissible.
Whenever ESI is offered as evidence, either at trial or in summary judgment, the following
evidence rules must be considered:

    (1) is the ESI relevant as determined by Rule 401 (does it have any tendency to make some
        fact that is of consequence to the litigation more or less probable than it otherwise would
        be);
    (2) if relevant under 401, is it authentic as required by Rule 901(a) (can the proponent show
        that the ESI is what it purports to be);
    (3) if the ESI is offered for its substantive truth, is it hearsay as defined by Rule 801, and if
        so, is it covered by an applicable exception (Rules 803, 804 and 807);
    (4) is the form of the ESI that is being offered as evidence an original or duplicate under the
        original writing rule, of if not, is there admissible secondary evidence to prove the
        content of the ESI (Rules 1001-1008); and
    (5) is the probative value of the ESI substantially outweighed by the danger of unfair
        prejudice or one of the other factors identified by Rule 403, such that it should be
        excluded despite its relevance.




June 15, 2010                                 36 | P a g e
   Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


Preliminarily, the process by which the admissibility of ESI is determined is governed by Rule
104, which addresses the relationship between the judge and the jury with regard to preliminary
fact finding associated with the admissibility of evidence. Because Rule 104 governs the very
process of determining admissibility of ESI, it must be considered first. See Lorraine, 241 F.R.D.
at 538.

Magistrate Judge Grimm summarizes the five distinct but interrelated evidentiary issues that
govern whether electronic evidence will be admitted into evidence at trial or accepted as an
exhibit in summary judgment practice, and counsels:

       Although each of these rules may not apply to every exhibit offered, as was the case here,
       each still must be considered in evaluating how to secure the admissibility of electronic
       evidence to support claims and defenses. Because it can be expected that electronic
       evidence will constitute much, if not most, of the evidence used in future motions
       practice or at trial, counsel should know how to get it right on the first try. The Court
       hopes that the explanation provided in this memorandum order will assist in that
       endeavor.

Read the full case at Lorraine v. Markel Am. Ins. Co., 241 F.R.D. 534 (D. Md. May 2007)

In summary and in pertaining to SPOLIATION OF EVIDENCE, there are numerous State of
California and Federal Precedents supporting that the operator of the Infrastructure has an
obligation to capture and store event and transaction data for the SmartGrid in a matter
which prevents any spoliation or tampering with the data.




                                    08-12-009 Service List



June 15, 2010                             37 | P a g e
       Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5



     This document was electronically served to the following on 6/15/2010, Witness my
     eHand. Todd S. Glassey


<ddayton@cleanenergysol.com>,                       <wbooth@booth-law.com>,
 <sesco@optonline.net>,                             <jerryl@abag.ca.gov>,
 <mmoore@newportpartnersllc.com>,                   <rknight@bki.com>,
 <keith.mccrea@sutherland.com>,                     <jody_london_consulting@earthlink.net>,
 <donaldgilligan@comcast.net>,                      <hoerner@redefiningprogress.org>,
 <mharrigan@ase.org>,                               <swentworth@oaklandnet.com>,
 <adam@agp-llc.com>,                                <samk@greenlining.org>,
 <michael@opower.com>,                              <TWhite@homeenergy.org>,
 <jimross@r-c-s-inc.com>,                           <john@proctoreng.com>,
 <rockybacchus@gmail.com>,                          <pmschwartz@sbcglobal.net>,
 <gtropsa@ice-energy.com>,                          <tim@marinemt.org>,
 <ckmitchell1@sbcglobal.net>,                       <wem@igc.org>,
 <SDPatrick@SempraUtilities.com>,                   <hankryan2003@yahoo.com>,
 <dmahmud@mwdh2o.com>,                              <bhines@svlg.net>,
 <nkarno@yahoo.com>,                                <Rob@ConSol.ws>,
 <thamilton@icfi.com>,                              <jweil@aglet.org>,
 <pwuebben@aqmd.gov>,                               <bill@jbsenergy.com>,
 <larry.cope@sce.com>,                              <elee@davisenergy.com>,
 <monica.ghattas@sce.com>,                          <mike@calcerts.com>,
 <CFPena@SempraUtilities.com>,                      <rnichols@navigantconsulting.com>,
 <liddell@energyattorney.com>,                      <tcrooks@mcr-group.com>,
 <andrew.mcallister@energycenter.org>,              <eemblem@3eintinc.net>,
 <dmano@enalasys.com>,                              <chris@cuwcc.org>,
 <etaylor@enalasys.com>,                            <mboccadoro@dolphingroup.org>,
 <mlewis@ctg-net.com>,                              <glw@eslawfirm.com>,
 <mike.rogers@greenhomesamerica.com>,               <jparks@smud.org>,
 <judi.schweitzer@post.harvard.edu>,                <ljimene@smud.org>,
 <rscott@cheers.org>,                               <bmatulich@egia.com>,
 <dale@betterbuildings.com>,                        <cscruton@energy.state.ca.us>,
 <wilkinson@es.ucsb.edu>,                           <kmills@cfbf.com>,
 <pcanessa@charter.net>,                            <rob@clfp.com>,
 <mtierney-lloyd@enernoc.com>,                      <steve@greenplumbersusa.com>,
 <JeffreyH@hellermanus.com>,                        <js@clearedgepower.com>,
 <RemiT@hellermanus.com>,                           <tom@ucons.com>,
 <dil@cpuc.ca.gov>,                                 <ABesa@SempraUtilities.com>,
 <jeanne.sole@sfgov.org>,                           <achang@efficiencycouncil.org>,
 <william.sanders@sfgov.org>,                       <WBlattner@SempraUtilities.com>,
 <bfinkelstein@turn.org>,                           <clamasbabbini@comverge.com>,
 <hayley@turn.org>,                                 <elvine@lbl.gov>,
 <marcel@turn.org>,                                 <gstaples@mendotagroup.net>,
 <mang@turn.org>,                                   <HYao@SempraUtilities.com>,
 <nlong@nrdc.org>,                                  <john@enactenergy.com>,
 <cjn3@pge.com>,                                    <mwbeck@lbl.gov>,
 <steven@moss.net>,                                 <PVillegas@SempraUtilities.com>,
 <jsqueri@goodinmacbride.com>,                      <sschiller@efficiencycouncil.org>,
 <edwardoneill@dwt.com>,                            <tglassey@certichron.com>,
 <jimflanagan4@mac.com>,                            <mrw@mrwassoc.com>,
 <saw0@pge.com>,                                    <cpuc@certichron.com>,
 <ssmyers@att.net>,                                 <EGrizard@deweysquare.com>,
 <jak@gepllc.com>,                                  <rekl@pge.com>,



     June 15, 2010                         38 | P a g e
         Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


<tam.hunt@gmail.com>,                                <david.gordon@efm-solutions.com>,
<gandhi.nikhil@verizon.net>,                         <kjk@kjkammerer.com>,
<ameliag@ensave.com>,                                <LukeH@enalasys.com>,
<Clark.Pierce@us.landisgyr.com>,                     <cneedham@edisonmission.com>,
<wjp4@bpconsulting.org>,                             <cperkins@energycoalition.org>,
<CCole@currentgroup.com>,                            <TFlanigan@EcoMotion.us>,
<emily.hallet@positiveenergy.com>,                   <sthompson@ci.irvine.ca.us>,
<puja@opower.com>,                                   <sbarata@opiniondynamics.com>,
<sean.harrington@opower.com>,                        <mlong@anaheim.net>,
<staples@staplesmarketing.com>,                      <cheryl.collart@ventura.org>,
<mking@staplesmarketing.com>,                        <Jeff.Hirsch@DOE2.com>,
<nphall@tecmarket.net>,                              <dmatson@co.santa-barbara.ca.us>,
<skihm@ecw.org>,                                     <hhuerta@rhainc.com>,
<annette.beitel@gmail.com>,                          <pk@utilitycostmanagement.com>,
<padib@apx.com>,                                     <atencate@rsgrp.com>,
<jmeyers@naima.org>,                                 <lcasentini@rsgrp.com>,
<pjacobs@buildingmetrics.biz>,                       <jcelona@sbcglobal.net>,
<bbarkett@summitblue.com>,                           <ann.kelly@sfgov.org>,
<mmcguire@summitblue.com>,                           <bruce.foster@sce.com>,
<bobbi.sterrett@swgas.com>,                          <matt@sustainablespaces.com>,
<emello@sppc.com>,                                   <norman.furuta@navy.mil>,
<David.Pettijohn@ladwp.com>,                         <eric@ethree.com>,
<bmcdonnell@mwdh2o.com>,                             <jchou@nrdc.org>,
<KWong@SempraUtilities.com>,                         <kgrenfell@nrdc.org>,
<KShore@SempraUtilities.com>,                        <lettenson@nrdc.org>,
<gclayborn@gmail.com>,                               <rlauman@ecosconsulting.com>,
<nhernandez@isd.co.la.ca.us>,                        <andrew_meiman@newcomb.cc>,
<kecia.davison@csgrp.com>,                           <ann_mccormick@newcomb.cc>,
<scott.bowman@csgrp.com>,                            <efm2@pge.com>,
<david@nemtzow.com>,                                 <yxg4@pge.com>,
<susan.munves@smgov.net>,                            <John_Newcomb@newcomb.cc>,
<jcluboff@lmi.net>,                                  <filings@a-klaw.com>,
<jack.rosenthal@p2seng.com>,                         <LDRi@pge.com>,
<brad.bergman@intergycorp.com>,                      <magnuson.leif@epa.gov>,
<southlandreports@earthlink.net>,                    <lhj2@pge.com>,
<cyin@yinsight.net>,                                 <matt_sullivan@newcomb.cc>,
<twayne@roadrunner.com>,                             <mpa@a-klaw.com>,
<sculbertson@icfi.com>,                              <nes@a-klaw.com>,
<don.arambula@sce.com>,                              <sls@a-klaw.com>,
<tory.weber@sce.com>,                                <tmfry@nexant.com>,
<devon@hartmanbaldwin.com>,                          <aliddell@icfi.com>,
<Case.Admin@sce.com>,                                <jared@efficiencyfirst.org>,
<Jennifer.Shigekawa@sce.com>,                        <cassandra.sweet@dowjones.com>,
<Laura.Genao@sce.com>,                               <mgo@goodinmacbride.com>,
<dwood8@cox.net>,                                    <sdhilton@stoel.com>,
<rsperberg@onsitenergy.com>,                         <policy.solutions@comcast.net>,
<jlaun@apogee.net>,                                  <cem@newsdata.com>,
<Elizabeth.DeSouza@csgrp.com>,                       <lisa_weinzimer@platts.com>,
<ashley.watkins@energycenter.org>,                   <M1ke@pge.com>,
<CentralFiles@SempraUtilities.com>,                  <slda@pge.com>,
<irene.stillings@energycenter.org>,                  <SRRd@pge.com>,
<jennifer.porter@energycenter.org>,                  <s1w2@pge.com>,
<sephra.ninow@energycenter.org>,                     <wmcguire@fypower.org>,
<CentralFiles@SempraUtilities.com>,                  <bkc7@pge.com>,
<JYamagata@SempraUtilities.com>,                     <regrelcpuccases@pge.com>,
<bob.ramirez@itron.com>,                                     <jkz1@pge.com>,
<rachel.harcharik@itron.com>,                                <rafi@pge.com>,


June 15, 2010                         39 | P a g e
         Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


        <epetrill@epri.com>,                                <ehebert@energy.state.ca.us>,
        <andrew.wood3@honeywell.com>,                       <jcastleberry@rs-e.com>,
        <sharon@emeter.com>,                                <wynne@braunlegal.com>,
        <kathleen.gaffney@kema.com>,                        <klewis@energy.state.ca.us>,
        <elowe@barakatconsulting.com>,                      <mharcos@rs-e.com>,
        <tlmurray@earthlink.net>,                           <rsapudar@energy.state.ca.us>,
        <singh70@gmail.com>,                                <bernardo@braunlegal.com>,
        <mistib@comcast.net>,                               <pstoner@lgc.org>,
        <ashish.goel@intergycorp.com>,                      <lmh@eslawfirm.com>,
        <grant.cooke@intergycorp.com>,                      <vwood@smud.org>,
        <jay.bhalla@intergycorp.com>,                       <jane@autocell.net>,
        <rfox@intergycorp.com>,                             <richard@autocell.net>,
        <sbeserra@sbcglobal.net>,                           <wwester@smud.org>,
        <ghamilton@gepllc.com>,                             <rmowris@earthlink.net>,
        <michael.cheng@paconsulting.com>,                   <hgilpeach@scanamerica.net>,
        <cadickerson@cadconsulting.biz>,                    <Dbjornskov@peci.org>,
        <alex.kang@itron.com>,                              <paul.notti@honeywell.com>,
        <Ann.Peterson@itron.com>,                           <brian.hedman@cadmusgroup.com>,
        <fred.coito@kema.com>,                              <Sami.Khawaja@cadmusgroup.com>,
        <jenna.canseco@us.kema.com>,                        <janep@researchintoaction.com>,
        <jennifer.fagan@itron.com>,                         <9watts@gmail.com>,
        <jtiffany@ase.org>,                                 <samsirkin@cs.com>,
        <john.cavalli@itron.com>,                           <mbaker@sbwconsulting.com>,
        <brbarkovich@earthlink.net>,                        <jholmes@emi1.com>,
        <Karin.Corfee@kema.com>,                            <jbazemore@emi1.com>,
        <Bruce@BuildItGreen.org>,                           <ppl@cpuc.ca.gov>,
        <awatson@quest-world.com>,                          <atr@cpuc.ca.gov>,
        <robertg@greenlining.org>,                          <aeo@cpuc.ca.gov>,
        <jskromer@qmail.com>,                               <cbe@cpuc.ca.gov>,
        <craigtyler@comcast.net>,                           <cf1@cpuc.ca.gov>,
        <darmanino@co.marin.ca.us>,                         <cxc@cpuc.ca.gov>,
        <michele@boggis.com>,                               <crv@cpuc.ca.gov>,
        <rita@ritanortonconsulting.com>,                    <dmg@cpuc.ca.gov>,
        <gthomas@ecoact.org>,                               <trh@cpuc.ca.gov>,
        <emahlon@ecoact.org>,                               <hcf@cpuc.ca.gov>,
        <michael@ecoact.org>,                               <jbf@cpuc.ca.gov>,
        <mary.tucker@sanjoseca.gov>,                        <jl2@cpuc.ca.gov>,
        <NancyKRod@conSol.ws>,                              <cln@cpuc.ca.gov>,
        <bobho@mid.org>,                                    <jst@cpuc.ca.gov>,
        <joyw@mid.org>,                                     <jnc@cpuc.ca.gov>,
        <gsenergy@sonoma-county.org>,                       <jdr@cpuc.ca.gov>,
        <tconlon@geopraxis.com>,                            <jci@cpuc.ca.gov>,
        <garrick@jbsenergy.com>,                            <keh@cpuc.ca.gov>,
        <bmfinkelor@ucdavis.edu>,                           "Mahoney, Kim" <kmb@cpuc.ca.gov>,
        <rmccann@umich.edu>,                                <ks3@cpuc.ca.gov>,
        <mbhunt@ucdavis.edu>,                               <lp1@cpuc.ca.gov>,
        <mgillette@enernoc.com>,                            <mmw@cpuc.ca.gov>,
        <dmahone@h-m-g.com>,                                <mkh@cpuc.ca.gov>,
        <kenneth.swain@navigantconsulting.com               <nfw@cpuc.ca.gov>,
>,                                                          <pw1@cpuc.ca.gov>,
        <kdusel@navigantconsulting.com>,                    <pcf@cpuc.ca.gov>,
        <lpark@navigantconsulting.com>,                     <snr@cpuc.ca.gov>,
        <david.reynolds@ncpa.com>,                          <srm@cpuc.ca.gov>,
        <scott.tomashefsky@ncpa.com>,                       <tcx@cpuc.ca.gov>,
        <asloan@rs-e.com>,                                  <tcr@cpuc.ca.gov>,
        <mclaughlin@braunlegal.com>,                        <zap@cpuc.ca.gov>,
        <dgeis@dolphingroup.org>,                           <ztc@cpuc.ca.gov>,


June 15, 2010                         40 | P a g e
         Petition to adopt, amend, or repeal a regulation pursuant to Pub. Util. Code § 1708.5


        <awp@cpuc.ca.gov>,                                   <sbender@energy.state.ca.us>,
        <crogers@energy.state.ca.us>,                        pbarthol@energy.state.ca.us,
        <agarcia@energy.state.ca.us>,                       <webdra@cpuc.ca.gov>
        <msherida@energy.state.ca.us>,




June 15, 2010                         41 | P a g e

				
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