Presentation on theme: "COM Operating Personnel Communications Protocols"— Presentation transcript:
1COM-002-4 Operating Personnel Communications Protocols Howard Gugel, Director of Standards Development, NERCOctober 30, 2013
2AgendaProject – BackgroundCOM RequirementsImplementation PlanComplianceVSL/VRF by RequirementRSAW NotesNext Steps
32003 Blackout Report Recommendation 26 Overview2003 Blackout Report Recommendation 26Tighten communications protocols, especially for communications during alerts and emergenciesFERC Order 693 directives on COM-002Add Distribution ProvidersRequire the Electric Reliability Organization (ERO) to establish tightened communication protocols, especially for communications during alerts and emergenciesCOM and COM developmentNERC Board of Trustees request for input from RISC, IERP and NERC Management
4BackgroundStandards Oversight and Technology Recommendation to BoardStandards Committee WaiverDevelopment of COM by Standard Drafting Team
5COM-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.
6COM-002-4: R1Applies to Balancing Authorities, Reliability Coordinators, and Transmission OperatorsRequires minimum set of protocols that must be included in documented communications protocols.Three part communicationsUse of English languageClarification for all call protocolsInstances where alpha-numeric and time designations are requiredNomenclature for interface Elements and FacilitiesAllows 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
7Applies to Distribution Providers and Generator Operators COM-002-4: R2Applies to Distribution Providers and Generator OperatorsRequires minimum set of protocols that must be included in documented communications protocols.Three part communicationsUse of English languageAll call protocolsThese entities included to require three part participation for receivers of Operating Instructions
8COM-002-4: R3, R4, R5Requirements 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.Explain why DP and GOP are not in R5
9Prerequisite Approval: Implementation PlanApproval:COM Operating Personnel Communications ProtocolsDefinition of Operating Instruction as well as addition to NERC Glossary of TermsPrerequisite Approval:Approval of definition of Reliability Directive as well as addition to NERC Glossary of TermsRetirements:COM‐001‐1.1 Requirement R4 – Telecommunications COM‐002‐2 – Communication and Coordination COM‐002‐3 – Communication and Coordination
10Types of Evidence Entities may provide ComplianceTypes of Evidence Entities may provideDescriptions of Management PracticesSpreadsheets, memos, logs, independent review of operating personnel’s adherence to protocols and remediation of exceptionsData RetentionOne Calendar Year for evidence demonstrating compliance for each applicable requirementExcept for Voice Recordings, which are required to be kept for 90 daysAuditor focus is primarily on internal controls and their effectiveness, not the actual communicationsOnly if auditor cannot gain reasonable assurance communication protocols are not being followed, then recordings will be examined
11VRF/VSL Range by Requirement 1LowLow to Severe2Moderate to Severe3HighHigh to Severe45Severe
12RSAW for the two implementation Requirements R3 and R4: RSAW NotesRSAW 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.
13Next StepsOct 25th -Nov 4th : Ballot and Non-binding PollNov 7th : NERC Board of Trustees Meeting