ANNUAL GENERAL ORDER 166 REPORT OF

LIBERTY UTILITIES (CALPECO ELECTRIC) LLC

Compliance Period: July 1, 2016 - June 30, 2017

Submitted by:

Daniel W. Marsh

Manager, Rates and Regulatory Affairs

Liberty Utilities (CalPeco Electric) LLC

933 Eloise Avenue

South Lake Tahoe CA, 96150

Telephone: (562) 299-5104

E-Mail: Dan.Marsh@libertyutilities.com

Dated: October 31, 2017

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ANNUAL GENERAL ORDER 166 REPORT OF

LIBERTY UTILITIES (CALPECO ELECTRIC) LLC

Compliance Period: July 1, 2016 – June 30, 2017

Introduction

Pursuant to General Order 166 (“G.O. 166”), Standard 11, Liberty Utilities (CalPeco

Electric) LLC (referenced as Liberty Utilities herein) hereby submits this report on its

compliance with G.O. 166 for the period July 1, 2016 through June 30, 2017 (“Compliance

Period”).

This report demonstrates Liberty Utilities compliance with each of the fourteen standards

of G.O. 166 from July 1, 2016 to June 30, 2017.

Liberty Utilities provides retail electric service to the public in the Lake Tahoe area of

California. In California, Liberty Utilities serves 49,000 customers, who are located in portions

of Placer, El Dorado, Nevada, Sierra, Plumas, Mono, and Alpine Counties. Its service territory

generally encompasses the western portions of the Lake Tahoe Basin ranging from Portola in the

north to Markleeville and Walker in the south; however, 80% of its customers are located in the

Lake Tahoe Basin. The terrain in the service territory is mountainous, with elevations ranging

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from 9,050 feet in Squaw Valley to just under 5,000 feet at Portola. Most of its customers are

located at elevations greater than 6,000 feet.

Liberty Utilities’ electric service area is divided into two districts for electric operations,

with individual service operations for each district. The first district is primarily comprised of

the South Tahoe service area, serving parts of El Dorado, Mono, and Alpine Counties, and is

served by Liberty Utilities’ South Lake Tahoe Operations located at 933 Eloise Avenue in South

Lake Tahoe, California. The second district is primarily comprised of the North Tahoe service

area, serving parts of Placer, Nevada, Sierra and Plumas County, and is served by Liberty

Utilities’ North Lake Tahoe District Operations located at 701 National Avenue in Tahoe Vista,

California. The two service areas work as independent control areas for distribution switching.

The primary transmission source for North Tahoe is from the 120 kV systems out of Truckee and

Verdi, California and the primary transmission source for South Tahoe is from the 120 kV

systems out of the Carson Valley in Nevada. There is very little distribution interconnection

between the two service areas. Because of the unique independent configuration, the service

areas operate as individual districts during emergencies.

Correspondence or communications regarding this report should be addressed to:

Daniel W. Marsh

Manager, Rates and Regulatory Affairs

Liberty Utilities (CalPeco Electric) LLC

933 Eloise Avenue

South Lake Tahoe CA, 96150

Telephone: (562) 299-5104

E-Mail: Dan.Marsh@libertyutilities.com

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Standard 1: Emergency Response Plan

Liberty Utilities developed and implemented a Corporate Emergency Management Plan

(“CEMP”) which covers each of the items specified in Standard 1. A copy of the plan is being

submitted along with this document that has been updated for personnel changes (Tab 1).

Revisions including an updated Emergency Activation Levels table have been incorporated into

this Revision 3 of the CEMP.

Liberty Utilities developed a Fire Prevention Plan to supplement elements of our CEMP

which has been updated with changes in personnel (Tab 2).

Standard 2: Mutual Assistance Agreements

Liberty Utilities has a Mutual Assistance Agreement with NV Energy, is party to the

Western Energy Institute Mutual Assistance Agreement (Tab 3), and has entered into the

California Utilities Emergency Association (“CUEA”) Mutual Assistance Agreement for

Electric services, and the CUEA Call Center Mutual Assistance Agreement, as requirements for

participation in these agreements are predicated on membership in CUEA (Tab 4).

Standard 3: Emergency Training and Exercises

Liberty Utilities did not conduct an internal formal annual training exercise testing the

CEMP. Liberty Utilities conducted a table top training exercise on October 12th, 2016

Standard 4: Communications Strategy

A. Liberty Utilities’ strategy for communicating with the media and customers is through a

phone and email contact list.

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B. Liberty Utilities’ strategy for communicating with government officials and departments

is contained in the “Emergency Plan Additional Elements” section of the Corporate

Emergency Management Plan (pages 7 to 10).

C. The electric distribution system that serves Liberty Utilities’ customers is not connected

to any California Independent System Operator (CAISO)-controlled or Transmission

Owner- operated electric grid. CAISO and California transmission emergencies do not

directly affect Liberty Utilities’ California customers because the primary electricity

generation and transmission are served from Nevada and a separate Northwest operating

grid. Liberty Utilities’ service territory is located within NV Energy’s Balancing Area.

NV Energy’s Transmission and Balancing Operations’ Center is continually in contact

with the CAISO and other Transmission Owners as part of the North America Electric

Reliability Council.

Standard 5: Activation Standard

For the period of July 1, 2016 to June 30, 2017, Liberty Utilities reported zero Major

Outages — defined as when at least 50% (i.e., 24,000) of Liberty Utilities’ serviceable customers

experience a simultaneous, non-momentary interruption of service.

Standard 6: Initial Notification Standard

For the period of July 1, 2016 to June 30, 2017, Liberty Utilities reported zero (0) Major

Outages as listed in Standard 5 above.

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Standard 7: Mutual Assistance Evaluation Standard

For the period of July 1, 2016 to June 30, 2017, this standard does not apply.

Standard 8: Major Outage and Restoration Estimate Communication Standard

During the period of July 1, 2016 to June 30, 2017, Liberty Utilities did not utilize its

established email notification system that communicates details of any event, should one occur,

with Local County and city personnel including fire department, law enforcement, and

emergency response personnel. This correspondence includes a report on the cause of the event,

the areas affected, and the estimated time of restoration. A final communication is sent out when

all systems are fully restored.

In addition, if an event were to occur that involved the circuits in NV Energy’s service

area, our team members would be in constant contact with NV Energy system control and

dispatch personnel to keep apprised of system restoration progress.

Standard 9: Personnel Redeployment Planning Standard

Liberty Utilities outlines the personnel and resource redeployment process under the

“Emergency Activation” (pages 5-7) and “Supplemental & Contingency Resources” (page 7)

sections of the Corporate Emergency Management Plan. As the development of Regional

Emergency Coordination Plans continues, the training and deployment of non-trade emergency

personnel will be addressed in the planning process.

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Standard 10: Annual Pre-Event Coordination Standard

Liberty Utilities’ representatives are active members of the Sierra Front Wildfire

Cooperators which meets every other month and represents Wildland Fire Agencies from

Nevada Division of Forestry, U.S. Forest Service, California Department of Forestry and Fire

Protection, California Emergency Management Agency’s Fire and Rescue Division, Bureau of

Land Management, and numerous local fire departments that work cooperatively in wildfire

management across seven (7) California and six (6) Nevada counties along the Sierra Nevada

Range.

Liberty Utilities is an active participant in the South Lake Tahoe Emergency

Management Committee and the North Lake Tahoe / Truckee Emergency Management

committee. These committees meet periodically throughout the year. Members come from other

local utilities, local county and city agencies, local law enforcement and fire department

personnel, and critical businesses such as our local hospitals.

Liberty Utilities is a member of the California Utilities Emergency Association

(“CUEA”). Liberty Utilities is also active with the California utilities in several other activities

relating to Mutual Assistance and Emergency Response.

Standard 11: Annual Report

The number of repair and maintenance personnel in each personnel classification, from

July 1, 2016 to June 30, 2017, is attached in Tab 5 to this report. Liberty Utilities has entered

into a Mutual Assistance Agreement with Eaton Corporation to inspect, repair, and maintain our

substation facilities.

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Standard 12: Restoration Performance Benchmark For A Measured Event

Liberty Utilities had fewer than 150,000 electric customers and is exempt from

application of this standard.

Standard 13: Call Center Benchmark For A Measured Event

Liberty Utilities had fewer than 150,000 electric customers and is exempt from

application of this standard.

Standard 14 (AB 1650):

In October 2013, Liberty Utilities presented our Emergency Management Plan and

Outage Communications Plan to local city, county, law enforcement, and fire department

personnel. Five (5) meetings were held throughout our service territory, which included

representatives from all seven (7) counties (Plumas, Sierra, Nevada, Placer, El Dorado, Alpine,

and Mono).

Respectfully submitted,

/s/ Daniel W. Marsh ______________________________

Daniel W. Marsh

Manager, Rates and Regulatory Affairs

Liberty Utilities (CalPeco Electric) LLC

933 Eloise Avenue

South Lake Tahoe CA, 96150

Telephone: (562) 299-5104

E-Mail: Dan.Marsh@libertyutilities.com

Dated: October 31, 2017

Tab 1

Corporate Emergency Management Plan

Liberty’s Corporate Emergency Management Plan is a confidential document and

has been redacted from Liberty’s public version of the GO 166 Report

Tab 2

Fire Prevention Plan

Liberty’s Fire Prevention Plan is a confidential document and has been redacted

from Liberty’s public version of the GO 166 Report

Tab 3

Western Region Mutual Assistance Agreement

Tab 4

Mutual Assistance Agreement Among Members of the

California Utilities Emergency Association

Tab 5

Personnel Report

Standard 11:

For the period of July 1, 2016 to June 30, 2017, the following chart below identifies Repair

and Maintenance personnel for each classification in each Liberty Utilities Service Area, and total

throughout the company for the current compliance period.

7/1/16 – 6/30/17 North Lake

Tahoe

South Lake

Tahoe

Total

Liberty Utilities O&M Personnel Liberty Utilities

Serviceman, Elec. 0 1 1

Lineman * 6 5 11

Troubleman 3 1 4

Troubleman/Meterman 0 1 1

Equipment Operator 1 0 1

Field Clerk (Universal Utilityworker) 1 1 2

Warehouse Clerk 0 1 1

Inspector 2 2 4

Mechanic 1 1 2

* Includes Foreman, General Foreman, Apprentices, and Contract Lineman.

DECLARATION OF DANIEL W. MARSH IN SUPPORT OF

THE CONFIDENTIAL TREATMENT OF

LIBERTY UTILITIES (CALPECO ELECTRIC) LLC ANNUAL GENERAL ORDER 166

REPORT

I, Daniel W. Marsh, declare:

1. I am the Manager of Rates & Regulatory Affairs at Liberty Utilities (CalPeco

Electric) LLC (“Liberty CalPeco”) and have been authorized by Gregory S. Sorensen,

President of Liberty CalPeco, to sign this declaration. This declaration is based on my

personal knowledge of the confidential information contained in the Annual General

Order 166 Report of Liberty Utilities (CalPeco Electric) LLC for Compliance Period:

July 1, 2016 - June 30, 2017, dated October 31, 2017 (“Annual GO 166 Report”).

2. Based on my knowledge and experience, I make this declaration seeking confidential

treatment for the confidential information contained in the Annual GO 166 Report.

3. The confidential information contained in the Annual GO 166 Report includes sensitive

security information, including information related to the emergency and fire prevention

procedures and policies.

4. Public Utilities Code § 583, protects the disclosure of confidential information provided

to the Commission unless specifically required to be open to public inspection. Under

the California Public Records Act (Cal. Gov’t Code § 6250 et seq.), such records of

intelligence information or security procedures are exempt from disclosure to the public. See Cal.

Gov’t. Code § 6254(f). In addition, under Public Utilities Code § 768.6(c)(2) regarding

emergency and disaster preparedness plans, the statute sets forth a procedure to prevent

the release of “sensitive security-related information in the electrical corporation's

emergency and disaster preparedness plan.” Lastly, the California Evidence Code §

1040(b) provides that information should not be disclosed if the disclosure of the information is