Relating to the resilience of the electric grid and certain municipalities.

Contracts

• Security Vendor Agreements: Review Master Service Agreements (MSAs) with private security firms. Amend Scopes of Work to explicitly require their participation in biennial tabletop exercises at no additional cost.
• Law Enforcement MOUs: Pursue formal Memorandums of Understanding with local Sheriff’s Offices or PDs. You need a contractual or written basis to prove you attempted coordination if they later fail to participate.
• Fuel Supply: Review "Force Majeure" clauses in natural gas and fuel supply contracts. Determine if "All Hazards" (specifically EMP or cyber-induced physical damage) are covered events.

Hiring/Training

• Mandatory Exercises: Operations teams must transition from standard load-shedding drills to "physical attack" simulations. These must be distinct events, not combined with weather preparedness drills.
• Security Clearances: If your technical leadership is nominated to the TGSC or its working groups, they must be eligible for and obtain federal secret security clearances.

Reporting & Record-Keeping

• ERCOT Attestation: You must file a written attestation to ERCOT after every biennial exercise confirming that law enforcement roles were identified. Failure to file triggers PUC administrative penalties.
• Data Segregation: TDSPs must maintain internal records of exercise scenarios but are explicitly *not* required to disclose specific critical substation locations to ERCOT during these exercises. Ensure your internal compliance logs segregate this sensitive data.

Fees & Costs

• Internal Costs: All costs for conducting exercises and coordinating with law enforcement are borne by the provider.
• Penalty Exposure: Failure to submit the attestation or conduct the exercise subjects the entity to PUC administrative penalties of up to $25,000 per violation, per day (Util. Code 15.023).