COM Operating Personnel Communications Protocols. October 31, 2013
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1 COM Operating Personnel Communications Protocols October 31, 2013
2 Agenda Introductory Remarks: Mark Lauby Project Background COM Requirements Implementation Plan Compliance VSL/VRF by Requirement RSAW Notes Next Steps 2
3 Background 2003 Blackout Report Recommendation 26 Tighten communications protocols, especially for communications during alerts and emergencies FERC Order 693 directives on COM 002 Add Distribution Providers Require the Electric Reliability Organization (ERO) to establish tightened communications protocols, especially for communications during alerts and emergencies COM and COM development NERC Board of Trustees request for input from RISC, IERP and NERC Management 3
4 Background Standards Oversight and Technology Committee Recommendation to Board Standards Committee Waiver Development of COM by Standard Drafting Team 4
5 COM-002-4: Scope of Communications Operating Instruction A command by operating personnel responsible for the Real time generation control and operation of the interconnected Bulk Electric System to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. A discussion of general information and of potential options or alternatives to resolve Bulk Electric System operating concerns is not a command and is not considered an Operating Instruction. A Reliability Directive is one type of an Operating Instruction. 5
6 COM-002-4: R1 Applies to Balancing Authorities, Reliability Coordinators, and Transmission Operators Requires minimum set of protocols that must be included in documented communications protocols. o Three part oral communications o Use of English language o Clarification for all call protocols o Instances where alpha numeric and time designations are required o Nomenclature for interface Elements and Facilities Allows entities the flexibility to specify additional protocols deemed necessary, but promotes uniformity in protocols Entities can draw on Operating Committee Guideline on communications for additional protocols 6
7 COM-002-4: R2 Applies to Distribution Providers and Generator Operators Requires minimum set of protocols that must be included in documented communications protocols o Three part communications o Use of English language o All call protocols These entities included to require three part participation for receivers of Operating Instructions 7
8 COM-002-4: R3, R4, R5 Requirements R3 and R4 require entities to implement the documented communications protocols. Requirement R5 requires BAs, RCs, and TOPs to implement a method to evaluate their communications protocols established in accordance with R1. 8
9 Implementation Plan Approval: COM Opera ng Personnel Communica ons Protocols Definition of Operating Instruction as well as addition to NERC Glossary of Terms Prerequisite Approval: Approval of definition of Reliability Directive as well as addition to NERC Glossary of Terms Retirements: COM Requirement R4 Telecommunications COM Communication and Coordination COM Communication and Coordination 9
10 Compliance Types of evidence entities may provide Descriptions of Management Practices Spreadsheets, memos, logs, independent review of operating personnel s adherence to protocols and remediation of exceptions Data Retention One Calendar Year for evidence demonstrating compliance for each applicable requirement Except for Voice Recordings, which are required to be kept for 90 days Auditor focus is primarily on communications protocols and their effectiveness, not the actual communications Recordings will be examined only if the auditor cannot gain reasonable assurance that the communications protocols are not being followed 10
11 VRF/VSL Range by Requirement Requirement VRF VSL Range 1 Low Low to Severe 2 Low Moderate to Severe 3 High High to Severe 4 High High to Severe 5 Low Severe 11
12 RSAW Notes RSAW for the two implementation Requirements R3 and R4: Entity must describe the management practices in place that provide the auditor reasonable assurance that protocols established are being followed. Evidence examples include spreadsheets, memos, or logs, evidencing periodic, independent review of operating personnel s adherence to the protocols established in Requirement R1 and the remediation of noted exceptions. Based on the assessment of risk and internal controls, audit approach could range from the exclusion of the implementation requirements from audit scope to the auditor reviewing a sample of voice recordings to ensure the protocols were followed. Sampling is not a part of the audit process unless the auditor determines that the communications protocols are not properly designed or are ineffective. 12
13 Next Steps Oct 25 th Nov 4 th : Ballot and Non binding Poll Nov 7 th : NERC Board of Trustees Meeting 13
14 14
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