COM-002-4 Operating Personnel Communications Protocols Howard Gugel, Director of Standards Development, NERC October 30, 2013

COM-002-4 Operating Personnel Communications ProtocolsHoward Gugel, Director of Standards Development, NERCOctober 30, 2013

RELIABILITY | ACCOUNTABILITY2

• Project 2007-02 – Background• COM-002-4 Requirements• Implementation Plan• Compliance • VSL/VRF by Requirement • RSAW Notes • Next Steps

Agenda


• 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

communication protocols, especially for communications during alerts and emergencies

• COM-002-3 and COM-003-1 development• NERC Board of Trustees request for input from RISC, IERP and

NERC Management

Overview


• Standards Oversight and Technology Recommendation to Board• Standards Committee Waiver • Development of COM-002-4 by Standard Drafting Team

Background


• 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.

COM-002-4: Scope of Communications


• 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 communicationso Use of English languageo Clarification for all call protocolso Instances where alpha-numeric and time designations are requiredo 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

COM-002-4: R1

Author

is this everything?


• Applies to Distribution Providers and Generator Operators• Requires minimum set of protocols that must be included in

documented communications protocols.o Three part communicationso Use of English languageo All call protocols

• These entities included to require three part participation for receivers of Operating Instructions

COM-002-4: R2


• Requirements R3 and R4 require entities implement the documented communications protocols.

• Requirement 5 requires BAs, RCs, and TOPs to implement a method to evaluate their communications protocols established in accordance with R1.

COM-002-4: R3, R4, R5


• Approval: COM-002-4-Operating Personnel Communications 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 001 1.1 Requirement R4 – Telecommunications ‐ ‐ COM 002 2 – Communication and Coordination ‐ ‐ COM 002 3 – Communication and Coordination‐ ‐

Implementation Plan


• 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 internal controls and their

effectiveness, not the actual communications• Only if auditor cannot gain reasonable assurance

communication protocols are not being followed, then recordings will be examined

Compliance


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


• RSAW for the two implementation Requirements R3 and R4: Entity must describe the management practices in place that provide

the entity 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 internal control is not properly designed or is ineffective.

RSAW Notes


Next Steps

• Oct 25th -Nov 4th : Ballot and Non-binding Poll

• Nov 7th : NERC Board of Trustees Meeting


Questions and Answers

Documents

COM-002-4 Operating Personnel Communications Protocols Howard Gugel, Director of Standards Development, NERC October 30, 2013