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pdfUNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. ____________
PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARDS
COM-001-2 AND COM-002-4
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
William H. Edwards
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
May 14, 2014
TABLE OF CONTENTS
I.
EXECUTIVE SUMMARY .................................................................................................... 2
II.
NOTICES AND COMMUNICATIONS ................................................................................ 5
III. BACKGROUND .................................................................................................................... 5
A.
Regulatory Framework ..................................................................................................... 5
B.
NERC Reliability Standards Development Procedure ..................................................... 6
IV. Reliability Standard Version History and Commission Directives ........................................ 7
A.
History of COM-001-1 and Associated Commission Directives ..................................... 7
B.
History of COM-002-2 and Associated Directives .......................................................... 9
C.
Revisions to COM Reliability Standards ....................................................................... 13
V.
1.
History of Project 2006-06 ......................................................................................... 13
2.
History of Project 2007-02 ......................................................................................... 14
JUSTIFICATION FOR APPROVAL .................................................................................. 14
A.
Proposed Reliability Standard COM-001-2 ................................................................... 15
1.
Purpose of Proposed Reliability Standard .................................................................. 15
2.
Requirements, Technical Basis and Defined Terms ................................................... 15
3.
Improvements Reflected in Proposed COM-001-2 .................................................... 18
4.
Proposed COM-001-2 Satisfies the Commission’s Directives................................... 20
5.
Revisions to Reliability Standard COM-001-1.1 ....................................................... 22
B.
C.
Proposed Reliability Standard COM-002-4 ................................................................... 23
1.
Purpose of Proposed Reliability Standard .................................................................. 23
2.
Standard Development History ................................................................................. 24
3.
Requirements, Technical Basis, and Defined Terms .................................................. 25
4.
Improvements Reflected in COM-002-4 .................................................................... 40
5.
Proposed COM-002-4 Satisfies the Commission’s Directives................................... 42
Enforceability of Proposed Reliability Standards .......................................................... 44
VI. CONCLUSION ..................................................................................................................... 44
i
TABLE OF CONTENTS
Exhibit A
Proposed Reliability Standard COM-001-2
Exhibit B
Proposed Reliability Standard COM-002-4
Exhibit C
Implementation Plan and Mapping Document (COM-001-2)
Exhibit D
Implementation Plan (COM-002-4)
Exhibit E
Mapping Document (COM-002-4)
Exhibit F
Order No. 672 Criteria (COM-001-2)
Exhibit G
Order No. 672 Criteria (COM-002-4)
Exhibit H
Rationale and Technical Justification (COM-002-4)
Exhibit I
Frequently Asked Questions Document (COM-002-4)
Exhibit J
Table of Issues and Directives (COM-002-4)
Exhibit K
Analysis of Violation Risk Factors and Violation Security Levels (COM-001-2)
Exhibit L
Analysis of Violation Risk Factors and Violation Security Levels (COM-002-4)
Exhibit M
Summary of Development History and Complete Record of Development (COM001-2)
Summary of Development History and Complete Record of Development (COM002-4)
Exhibit N
Exhibit O
NERC Board of Trustees Input Responses
Exhibit P
Standard Drafting Team Rosters for Project 2006-06 Reliability Coordination and
Project 2007-02 Operating Personnel Communications Protocols
Exhibit Q
Operating Committee Reliability Guideline: “System Operator Verbal
Communications – Current Industry Practices”
ii
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. ____________
PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARDS
COM-001-2 AND COM-002-4
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”)3 hereby submits for Commission approval
proposed Reliability Standards COM-001-2 (Communications) (Exhibit A) and COM-002-4
(Operating Personnel Communications Protocols) (Exhibit B). NERC requests that the
Commission approve the proposed Reliability Standards and find that each is just, reasonable,
not unduly discriminatory or preferential, and in the public interest.4 NERC also requests
approval of: (i) new defined terms “Operation Instruction”, “Interpersonal Communication”, and
“Alternative Interpersonal Communication” for inclusion in the NERC Glossary of Terms; (ii)
the Implementation Plans for the proposed Reliability Standards (Exhibits C and D); (iii) the
associated Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibits A,
1
16 U.S.C. § 824o (2012).
18 C.F.R. § 39.5 (2014).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4
Unless otherwise designated, capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards (“NERC Glossary of Terms”), available at
http://www.nerc.com/files/Glossary_of_Terms.pdf.
2
1
B, K, and L); and (iv) the retirement of the currently-effective Reliability Standards COM-0011.1, EOP-008-1 (Requirement R1), and COM-002-2 as listed in the Implementation Plans.
As required by Section 39.5(a)5 of the Commission’s regulations, this petition presents
the technical basis and purpose of proposed Reliability Standards COM-001-2 and COM-002-4,
a summary of the development history for each proposed Reliability Standard (Exhibits M and
N), and a demonstration that the proposed Reliability Standards meet the criteria identified by
the Commission in Order No. 6726 (Exhibits F and G). The NERC Board of Trustees adopted
proposed Reliability Standards COM-001-2 and COM-002-4 on November 7, 2012 and May 6,
2014 respectively.
I.
EXECUTIVE SUMMARY
Proposed Reliability Standards COM-001-2 and COM-002-4 replace and improve upon
the currently effective COM-001-1.1 and COM-002-2 Reliability Standards to establish
requirements for communication capabilities and communications protocols necessary to
maintain reliability. Proposed COM-001-2 establishes a clear set of requirements for what
communications capabilities various functional entities must maintain for reliable
communications.
Proposed COM-002-4 requires entities to have or create a set of documented
communications protocols that include certain minimum mandatory protocols. Proposed COM002-4 improves communications surrounding the issuance of Operating Instructions by
employing predefined communications protocols, thereby reducing the possibility of
5
18 C.F.R. § 39.5(a) (2014).
The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
6
2
miscommunication that could lead to action or inaction harmful to the reliability of the Bulk
Electric System. In addition to setting predefined communications protocols, the proposed
Reliability Standard requires use of the same protocols regardless of the current operating
condition. In other words, the same protocols apply during normal, alert, and Emergency
operating conditions, negating the need to identify the current operating condition to determine if
a different set of protocols applies.
Proposed COM-002-4 also requires entities to reinforce
the use of the documented communication protocols through training, assessing adherence by
operating personnel to the documented communication protocols, and providing feedback to
those operating personnel on their use of the protocols. During Emergencies, operating personnel
must use the documented communication protocols for three-part communications without
exception, since clear communication is essential to providing swift and coordinated response to
events that are directly impacting the reliability of the Bulk Electric System.
Proposed Reliability Standards COM-001-2 and COM-002-4 address all of the pertinent
Commission directives from Order No. 693 associated with the Commission’s approval of
COM-001-1.1 and COM-002-2.7 The revisions made to proposed COM-002-4 also address
Recommendation No. 26 from the final report issued by the U.S.-Canada Power System Outage
Task Force to “[t]ighten communications protocols, especially for communications during alerts
and emergencies.”8
7
Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 Fed. Reg.
16416, FERC Stats. & Regs. ¶ 31,242, at PP 487-93, 502-04, 508, 512, 514-15, 531-32, 534, 535, and 540, order on
reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
8
U.S.-Canada Power System Outage Task Force, Final Report on the August 14, 2003 Blackout in the
United States and Canada: Causes and Recommendations, April 2004 (“Blackout Report”). On August 15, 2003,
President George W. Bush and then-Prime Minister Jean Chrétien directed the creation of a Joint U.S.-Canada
Power System Outage Task Force to investigate the causes of the blackout and ways to reduce the possibility of
future outages. The U.S.-Canada Task Force convened, investigated the causes of this blackout, and recommended
actions to prevent future widespread outages.
3
Proposed COM-001-2 satisfies the Commission’s directives and improves upon
Reliability Standard COM-001-1.1 by adding Generator Operators and Distribution Providers as
applicable entities. Proposed COM-001-2 also identifies specific requirements for
telecommunications capabilities for use in all operating conditions that reflect the roles of the
applicable entities and their impact on Reliable Operation. Proposed COM-001-2 further
includes adequate flexibility in its language for compliance with the Reliability Standard to
permit the adoption of new technologies and cost-effective solutions.
Proposed COM-002-4 also satisfies the Commission’s directives and improves upon the
previous Reliability Standard COM-002-2 by adding Distribution Providers as an applicable
entity in the proposed Reliability Standard. Proposed COM-002-4 also meets the Commission’s
directive to require “tightened communications protocols, especially for communications during
alerts and emergencies” by establishing a baseline set of mandatory protocols and focusing
certain requirements on zero-tolerance responsibility for failure to use or misuse of the protocols
for three-part communications during Emergency conditions. Under proposed COM-002-4, all
applicable entities must use the same set of protocols during all operating conditions,
establishing communication uniformity as much as practical on a continent-wide basis.
For the reasons discussed in this Petition, NERC respectfully requests that the
Commission approve the proposed Reliability Standards as just, reasonable, not unduly
discriminatory or preferential, and in the public interest.
4
II.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the
following:9
Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Associate General Counsel
William H. Edwards*
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
III.
Valerie L. Agnew*
Director of Standards
Howard Gugel*
Director, Performance Analysis
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
[email protected]
[email protected]
BACKGROUND
A.
Regulatory Framework
By enacting the Energy Policy Act of 2005,10 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)11
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
9
Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2014), to allow the inclusion
of more than two persons on the service list in this proceeding.
10
16 U.S.C. § 824o (2012).
11
Id. § 824(b)(1).
5
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5)12 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability
Standard. Section 39.5(a)13 of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA14 and Section 39.5(c)15 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the
content of a Reliability Standard.
B.
NERC Reliability Standards Development Procedure
The proposed Reliability Standards were developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.16 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
12
Id. § 824o(d)(5).
18 C.F.R. § 39.5(a).
14
16 U.S.C. § 824o(d)(2).
15
18 C.F.R. § 39.5(c)(1).
16
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672 at P 334, FERC Stats. &
Regs. ¶ 31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006) (“Further, in considering
whether a proposed Reliability Standard meets the legal standard of review, we will entertain comments about
whether the ERO implemented its Commission-approved Reliability Standard development process for the
development of the particular proposed Reliability Standard in a proper manner, especially whether the process was
open and fair. However, we caution that we will not be sympathetic to arguments by interested parties that choose,
for whatever reason, not to participate in the ERO’s Reliability Standard development process if it is conducted in
good faith in accordance with the procedures approved by FERC.”).
13
6
Development) of its Rules of Procedure and the NERC Standard Processes Manual.17 In its
order certifying NERC as the Commission’s Electric Reliability Organization, the Commission
found that NERC’s proposed rules provide for reasonable notice and opportunity for public
comment, due process, openness, and a balance of interests in developing Reliability Standards18
and thus satisfies certain of the criteria for approving Reliability Standards.19 The development
process is open to any person or entity with a legitimate interest in the reliability of the BulkPower System. NERC considers the comments of all stakeholders, and a vote of stakeholders
and the NERC Board of Trustees is required to approve a Reliability Standard before the
Reliability Standard is submitted to the Commission for approval.
IV.
Reliability Standard Version History and Commission Directives
This section presents the version history of each Reliability Standard beginning with the
version 0 Reliability Standards and the associated Commission directives from Order No. 693.
NERC has also included relevant discussion from the Order No. 693 proceeding that has
relevance to both the directives and the standards development work of the standard drafting
teams to revise the COM-001 and COM-002 Reliability Standards. Discussion of the proposed
Reliability Standards and how the proposed Reliability Standards satisfy the Commission
directives is included below in section V of this Petition.
A.
History of COM-001-1 and Associated Commission Directives
NERC originally implemented Reliability Standard COM-001-0 (Telecommunications)
on April 1, 2005.20 The version 0 Reliability Standard sought to ensure coordinated
17
The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.
18
116 FERC ¶ 61,062 at P 250.
19
Order No. 672 at PP 268, 270.
20
See NERC Apr. 4, 2006 Petition for Approval of Reliability Standards, Docket No. RM06-16-000 at 33.
7
telecommunications among operating entities and established general telecommunications
requirements for operating entities, including equipment testing and coordination. COM-001-0
also: (i) established English as the common language between and among operating personnel;
and (ii) set the policy for using the NERCnet telecommunications system.21 COM-001-0 applied
to Transmission Operators, Balancing Authorities, Reliability Coordinators and NERCNet user
organizations.22 NERC submitted COM-001-0 in its original petition for approval of its
proposed Reliability Standards.23 NERC subsequently submitted a petition24 to include a revised
version 1 of the COM-001 Reliability Standard to add missing compliance elements.25
On May 11, 2006, Commission staff issued its Staff Preliminary Assessment of the North
American Electric Reliability Council’s Proposed Mandatory Reliability Standards
(“Preliminary Assessment”).26 In the Preliminary Assessment, Commission staff made the
following summary comments regarding COM-001-0:
•
COM-001-0 does not contain specific or minimum adequacy, redundancy and diverse
routing requirements for telecommunications facilities;
•
the applicability section does not specify that Generator Operators are subject to
telecommunications requirements; and
•
COM-001-0 contains no Compliance Measures or Levels of Non-Compliance.
21
NERCNet is a Wide Area Network using Frame Relay as its communications medium. It supports the
Interregional Security Network, Interchange Distribution Calculator and the Reliability Coordinator Information
System. NERCnet has been used by NERC since 1997 to allow Reliability Coordinators, Transmission Operators,
and Balancing Authorities and NERCnet user organizations to share Real-time operating reliability data.
22
“NERCnet User Organizations” are defined in COM-001-1.1, Attachment 1 as “[us]ers of NERCnet who
have received authorization from NERC to access the NERC network are considered users of NERCnet resources.
To be granted access, users shall complete a User Application Form and submit this form to the NERC
Telecommunications Manager.”
23
See NERC Apr. 4, 2006 Petition for Approval of Reliability Standards, Docket No. RM06-16-000.
24
See NERC Nov. 16, 2006 Petition for Approval of Reliability Standards, Docket Nos. RM06-16-000 and
RM07-03-000.
25
The Commission approved an errata change to COM-001-1 by delegated letter order on May 13, 2009. As
a result, the currently effective and enforceable version of COM-001 is COM-001-1.1. See N. Am. Elec. Reliability
Corp., Docket No. RD09-2-000 (2009) (delegated letter order).
26
See Staff Preliminary Assessment of the North American Electric Reliability Council’s Proposed
Mandatory Reliability Standards, May 11, 2006, Docket No. RM06-16-000.
8
Commission staff explained in the Preliminary Assessment that COM-001 contains a general
requirement to provide “adequate and reliable” telecommunications facilities for all applicable
operating entities. Commission staff concluded that COM-001-0 does not contain specific or
minimum requirements on adequacy, redundancy and diverse routing of the telecommunications
facilities necessary to ensure the exchange of operating information, both internally and among
operating entities. Staff explained that leaving the specification of what constitutes adequate and
reliable telecommunication facilities to operating entities could lead to claims by operating
entities that they comply with the Reliability Standard when in fact they still may not have
“adequate” telecommunications facilities for use during real-time normal and Emergency
operations.27 Further, Commission staff noted that while COM-001 has a redundancy and
diverse routing requirement, it is effective only “where applicable,” and no specification is
provided regarding the circumstances where the requirement actually is applicable.
The Commission approved COM-001-1 in Order No. 693, but the Commission issued
certain directives to improve the Reliability Standard including the additional of certain entities
to the applicability of the standard and identification of specific requirements for
telecommunications facilities.28
B.
History of COM-002-2 and Associated Directives
Reliability Standard COM-002-0 was implemented on April 1, 2005. The stated purpose
of the Reliability Standard was to:
To ensure Balancing Authorities, Transmission Operators, and
Generator Operators have adequate communications and that these
communications capabilities are staffed and available for addressing
a real-time emergency condition. To ensure communications by
operating personnel are effective.
27
28
Id. at 42-43.
Order No. 693 at PP 487-93, 502-04, 508.
9
COM-002-0 applied to Reliability Coordinators, Balancing Authorities, Transmission Operators,
and Generator Operators. Reliability Standard COM-002-1 was developed in November 2006 to
replace COM-002-0. COM-002-1 added additional detail on the communications requirements
between and among operating entities and included specific situations that require
communications with other operating entities. COM-002-1 contained two Requirements.
Requirement R1 required each Transmission Operator, Balancing Authority, and Generator
Operator to have communications (voice and data links) with appropriate Reliability
Coordinators, Balancing Authorities, and Transmission Operators. The communications had to
be staffed and available for addressing a real-time emergency condition. In addition, each
Balancing Authority and Transmission Operator had to notify its Reliability Coordinator and
affected Balancing Authorities and Transmission Operators “of any condition that could threaten
the reliability of its area or when firm load shedding is anticipated.” Requirement R2 required
each Reliability Coordinator, Transmission Operator, and Balancing Authority to use three-part
communications. Each entity was required to issue directives in a clear, concise, and definitive
manner; ensure the recipient of the directive repeats the information back correctly; and
acknowledge the response as correct or repeat the original statement to resolve any
misunderstandings.29
NERC submitted COM-002-1 in its original petition for approval of its proposed
Reliability Standards.30 In its subsequent November 15, 2006 petition, NERC submitted COM002-2, which supersedes the version 1 Reliability Standard. COM-002-2 adds Measures and
Levels of Non-Compliance to the version 1 Reliability Standard.
29
Of particular note, the Reliability Standard did not place any obligation on the receiver of a
communication. The responsibility for ensuring proper understanding was placed on the issuer.
30
See NERC Apr. 4, 2006 Petition for Approval of Reliability Standards, Docket No. RM06-16-000 at 32-33.
10
The Preliminary Assessment issued by FERC staff also identified shortcomings in the
COM-002-2 Reliability Standard. Commission staff stated that the standard did not contain a
requirement that appropriate operating actions be assessed and approved first and then
implemented in normal and emergency operating conditions in which reliability could be
impacted beyond a local area. Commission staff noted in its explanation “[e]ffective
communications with proper communications protocols among the operating entities are
essential for maintaining reliable system operations.”
Commission staff’s comments relied heavily on recommendations made in the Blackout
Report. The Blackout Report included 46 specific recommendations to address the primary
causes of the blackout to help prevent or minimize the scale of future blackouts. The Blackout
Report also identified eight factors that were common to some of the eight major outage
occurrences from the 1965 Northeast Blackout through the 2003 blackout, including “ineffective
communications.”31 In particular, Recommendation No. 26 reads: “[t]ighten communications
protocols, especially for communications during alerts and emergencies. Upgrade
communication system hardware where appropriate.” Recommendation No. 26 continues:
NERC should work with reliability coordinators and control area
operators to improve the effectiveness of internal and external
communications during alerts, emergencies, or other critical situations,
and ensure that all key parties, including state and local officials,
receive timely and accurate information. NERC should task the
regional councils to work together to develop communications
protocols by December 31, 2004, and to assess and report on the
adequacy of emergency communications systems within their regions
against the protocols by that date.32
The Blackout Report explained that on August 14, 2003, “reliability coordinator and control area
communications regarding conditions in northeastern Ohio were in some cases ineffective,
31
32
Blackout Report at 107.
Id. at 141, 161.
11
unprofessional, and confusing.” The Blackout Report concluded that ineffective communications
contributed to a lack of situational awareness and precluded effective actions to prevent the
cascade. The Blackout Report also stated “[c]onsistent application of effective communications
protocols, particularly during alerts and emergencies, is essential to reliability.”33
In its Preliminary Assessment, Commission staff interpreted the Blackout Report
recommendation’s reference to “effective communications” with “tightened communications
protocols” among operating entities to include two key components: (i) effective
communications that are delivered in clear language via pre-established communications paths
among pre-identified operating entities, and (ii) communications protocols which clearly identify
that any operating actions with reliability impact beyond a local area or beyond a Reliability
Coordinator’s area must be communicated to the appropriate Reliability Coordinator for
assessment and approval prior to their implementation to ensure reliability of the interconnected
systems.34 Commission staff concludes that the requirements in COM-002-1 fulfill the
“effective communications” component of the Blackout Report recommendation, but do not
meet the call for “tightened communications protocols.” Specifically, the Commission states that
COM-002-1, or other Reliability Standards, do not contain a requirement that the appropriate
operating actions in normal and emergency operating conditions that may have reliability impact
beyond a local area or Reliability Coordinator’s area must be assessed and approved by the
Reliability Coordinator, before implementation by the operating entities.35
In its comments to the Preliminary Assessment, NERC stated that it did not believe that
“tightened communications protocols” should include the requirement that “the appropriate
33
34
35
Id. at 161.
Preliminary Assessment at 43-44.
Id. at 44.
12
operating actions…must be assessed and approved by the reliability coordinator, before being
implemented by the operating entities.”36 NERC further argued that other NERC standards (e.g.,
EOP-001 and TOP-001) require the Transmission Operator, Balancing Authority, and Reliability
Coordinator to coordinate their emergency operating plans and communicate actions with one
another. However, NERC did state, without elaboration, that it “agrees with the need for
development of additional standards addressing consistent communications protocols among
personnel responsible for the reliability of the Bulk-Power System.”
The Commission ultimately approved COM-002-2 in Order No. 693, but the Commission
issued certain directives to improve the Reliability Standard including adding Distribution
Providers as an applicable entity in the Reliability Standard and requiring NERC to create
tightened communications protocols, especially for communications during alerts and
emergencies.37 Section V includes a summary of these directives along with how the proposed
Reliability Standard satisfies the directives.
C.
Revisions to COM Reliability Standards
1.
History of Project 2006-06
Project 2006-06 – Reliability Coordination was established to ensure that reliabilityrelated Requirements that are applicable to the Reliability Coordinator are clear, measurable,
unique and enforceable, and to ensure that this set of Requirements is sufficient to maintain
36
NERC Jun. 26, 2006 Comments to Preliminary Assessment, Docket No. RM06-16-000 at 120 (quoting
Preliminary Assessment) (emphasis added).
37
In addition, the Commission suggests NERC consider certain comments in the Standards Development
Process. The Commission asks NERC to consider the American Public Power Association’s (“APPA”) comments
regarding the Measures and Levels of Non-Compliance when revising the Reliability Standard. APPA notes that the
Levels of Non-Compliance for COM-002-2 are inadequate in two respects: (1) reliability coordinators are not
included in any Level of Non-Compliance and (2) the Levels of Non-Compliance for transmission operators and
balancing authorities in Compliance D.2 do not reference Requirements R1 and R2. Order No. 693 at P 533. The
Commission also suggest that NERC consider comments by Santa Clara, FirstEnergy and Six Cities regarding
specific new improvements to the Reliability Standards. Order No. 693 at 536-39.
13
reliability of the Bulk Electric System. Revisions to the COM-001 and COM-002 Reliability
Standards were included within the project scope in order to modify the currently-effective
Reliability Standards, COM-001-1.1 and COM-002-2, to address the applicable directives in
Order No. 693, while adequately addressing the communication needs of Reliability
Coordinators. The project resulted in two proposed Reliability Standards, COM-001-2 and
COM-002-3.
2.
History of Project 2007-02
The purpose of Project 2007-02 – Operating Personnel Communications Protocols was to
create a new Reliability Standard that requires real time system operators to use standardized
communication protocols during normal and emergency operations to improve situational
awareness and shorten response time.38 The Project drafted Reliability Standard COM-003-1 to
accomplish this goal. The Project ultimately resulted in the combination of COM-002-3 from
Project 2006-06 and draft COM-003-1 into a single proposed Reliability Standard, COM-002-4.
V.
JUSTIFICATION FOR APPROVAL
As discussed in Exhibits F and G and below, the proposed Reliability Standards, COM-
001-2 and COM-002-4, satisfy the Commission’s criteria in Order No. 672 and are just,
reasonable, not unduly discriminatory or preferential, and in the public interest. The following
section separately provides: (i) the purpose of the proposed Reliability Standards; (ii) a
description of the requirements in each of the proposed Reliability Standards, the technical basis
supporting the requirements, and a description of proposed defined terms; (iii) a discussion of
38
See Standard Authorization Request, available at
http://www.nerc.com/pa/Stand/Project%20200702%20Operating%20Personnel%20Communications/SAR_Project_
2007-02_Comm_Protocols_1st_Posting_15Mar07.pdf.
14
how the proposed Reliability Standards satisfy the outstanding Commission directives from
Order No. 693; and (iv) a discussion of the enforceability of the proposed Reliability Standards.
A.
Proposed Reliability Standard COM-001-2
1.
Purpose of Proposed Reliability Standard
Proposed Reliability Standard COM-001-2 revises the currently effective COM-001-1.1
Reliability Standard. The purpose of proposed Reliability Standard COM-001-2 is to establish
requirements for Interpersonal Communication capabilities necessary to maintain reliability.
Proposed COM-001-2 applies to Reliability Coordinators, Balancing Authorities, Transmission
Operators, Generator Operators, and Distribution Providers.
2.
Requirements, Technical Basis and Defined Terms
The proposed Reliability Standard includes eleven requirements and two new defined
terms, “Interpersonal Communication” and “Alternative Interpersonal Communication,” which
collectively provide a comprehensive approach to establishing communications capabilities
necessary to maintain reliability. The defined terms used in the requirements of proposed COM001-2 are:
Interpersonal Communication – Any medium that allows two or
more individuals to interact, consult, or exchange information.
Alternative Interpersonal Communication – Any Interpersonal
Communication that is able to serve as a substitute for, and does not
utilize the same infrastructure (medium) as, Interpersonal
Communication used for day-to-day operation.
These definitions provide clarity that an entity’s communication capability must be
redundant and that each of the capabilities must not utilize the same medium. The new
definitions, therefore, improve upon the language used in the current COM-001-1.1 Reliability
Standard, which states “[e]ach Reliability Coordinator, Transmission Operator and Balancing
15
Authority shall provide adequate and reliable telecommunications facilities for the exchange of
Interconnection and operating information.” COM-001-1.1, Requirement R1, Part R1.4 states
that “[w]here applicable, these facilities shall be redundant and diversely routed.” Use of the
defined terms eliminates the need to use the ambiguous phrases “adequate and reliable” and
“redundant and diversely routed, which were identified in the Preliminary Assessment as
potentially creating ambiguity in the Reliability Standard.
Requirements R1-R6 address the Interpersonal Communication capability and
Alternative Interpersonal Communication capability of the Reliability Coordinator, Transmission
Operator, and Balancing Authority. Each functional entity has a requirement to have an
Interpersonal Communication capability and to designate an Alternative Interpersonal
Communication capability with certain other functional entities as follows:
Requirements R1 and R2 require the Reliability Coordinator to have Interpersonal
Communication capability (R1) and designate Alternative Interpersonal Communication
capability (R2) with all Transmission Operators and Balancing Authorities within its Reliability
Coordinator Area and each adjacent Reliability Coordinator within the same Interconnection.
Requirement R3 requires each Transmission Operator to have Interpersonal
Communication capability with: (i) its Reliability Coordinator; (ii) each Balancing Authority
within its Transmission Operator Area; (iii) each Distribution Provider within its Transmission
Operator Area; (iv) each Generator Operator within its Transmission Operator Area; (v) each
adjacent Transmission Operator synchronously connected; and (vi) each adjacent Transmission
Operator asynchronously connected.
Requirement R4 requires each Transmission Operator to designate Alternative
Interpersonal Communication capability with: (i) its Reliability Coordinator; (ii) each Balancing
16
Authority within its Transmission Operator Area; (iii) each adjacent Transmission Operator
synchronously connected; and (iv) each adjacent Transmission Operator asynchronously
connected.
Requirement R5 requires each Balancing Authority to have Interpersonal Communication
capability with: (i) its Reliability Coordinator; (ii) each Transmission Operator that operates
Facilities within its Balancing Authority Area; (iv) each Distribution Provider within its
Balancing Authority Area; (v) each Generator Operator that operates Facilities within its
Balancing Authority Area; and (vi) each Adjacent Balancing Authority.
Requirement R6 requires each Balancing Authority to designate Alternative Interpersonal
Communication capability with: (i) its Reliability Coordinator; (ii) each Transmission Operator
that operates Facilities within its Balancing Authority Area; and (iii) each Adjacent Balancing
Authority.
Requirements R7 and R8 require each Distribution Provider and Generator Operator,
respectively, to have Interpersonal Communication capability with: (i) its Balancing Authority;
and (ii) its Transmission Operator.
Requirement R9 requires the Reliability Coordinator, Transmission Operator, and
Balancing Authority to test its Alternative Interpersonal Communication capability, initiate
repair, or designate a replacement alternative communication capability within two hours
following the test.
Requirement R10 requires the same entities to notify the entities identified in
Requirements R1, R3, and R5 of the detection of a failure of its Interpersonal Communication
capability that lasts 30 minutes or longer. The notification must occur within 60 minutes of the
detection of the failure. The standard drafting team determined that 60 minutes was a reasonable
17
timeframe for completing the notification. Some commenters in the standards development
process expressed concern in meeting the 60-minute notification timeframe upon the loss of their
Interpersonal Communication capability. However, the standard drafting team responded that the
notification requirement applies to the Balancing Authority, Reliability Coordinator and
Transmission Operator, which are required to have an Alternative Interpersonal Communication
capability, and should have the ability to accomplish the required notification.
Finally, Requirement R11 requires the Distribution Provider and Generator Operator to
consult with its Balancing Authority and Transmission Operator, upon detecting a failure of its
Interpersonal Communication capability, to determine a mutually agreeable action for the
restoration of its Interpersonal Communication capability. This requirement provides a means
for the Distribution Provider and Generator Operator to have an understanding with the
Balancing Authority and Transmission Operator of how the restoration of the Interpersonal
Communication capability will occur, providing the necessary awareness to all of the status of
the Interpersonal Communication capability.
3.
Improvements Reflected in Proposed COM-001-2
Proposed COM-001-2 improves the currently-effective Reliability Standard by: (1)
eliminating terms that do not adequately specify the desired actions that Reliability Coordinators,
Balancing Authorities, and Transmission Operators are expected to take in relation to their
telecommunication facilities; (2) clearly identifying the need for applicable entities to be capable
of Interpersonal Communication and Alternative Interpersonal Communication, as those terms
are defined and proposed for approval; (3) not requiring specific technology or systems to be
utilized; and (4) including the Distribution Provider and Generator Operator as covered
functional entities.
18
First, proposed COM-001-2 eliminates ambiguous terms used in COM-001-1 that do not
adequately specify the desired actions that Reliability Coordinators, Balancing Authorities, and
Transmission Operators are expected to take with respect to each’s telecommunication facilities.
For example, Requirement R1 of COM-001-1 includes the phrase “shall provide adequate and
reliable telecommunications facilities.” Entities explained during the Standards Development
Process that “adequate and reliable” could lend itself to multiple interpretations. The
Commission also raised concern over this phrase in the Preliminary Assessment prior to the
issuance of Order No. 693. Rather than using the term “adequate,” the proposed standard now
specifies the communications capability requirements between entities by function and condition
in Requirements R1 through R8. The term “reliable” is replaced by a specific requirement for
testing (Requirement R9), along with two new requirements for notification of a failure of an
applicable entity’s communication capability (Requirements R10 and R11). Further, use of two
new proposed defined terms – “Interpersonal Communication” and “Alternative Interpersonal
Communication” – resolves the ambiguity caused by the phrases “adequate and reliable” and
“redundant and diversely routed” communications in COM-001-1. COM-001-2 instead requires
the applicable entities to have a clearly defined Interpersonal Communication capability and an
Alternative Interpersonal Communication capability, in addition to specifying, under what
conditions, those entities that must have the capability.
Second, proposed COM-001-2 clearly identifies the need to be capable of both
Interpersonal Communication and Alternative Interpersonal Communication. By clearly
identifying the capability needs, the proposed Reliability Standard eliminates the inferred need
for redundant, emergency telecommunication facilities. In contrast, Requirement R2 of COM001-1, states “[s]pecial attention shall be given to emergency telecommunications facilities and
19
equipment not used for routine communications.” While this language contains an inference that
some equipment is maintained for uses other than routine communications, the requirement is
not clear about what capabilities must be maintained. The new term “Alternative Interpersonal
Communication” clarifies this language to explicitly require Interpersonal Communication
capabilities that does not utilize the same infrastructure as the communications infrastructure for
day-to-day operations.
Third, the use of word “capability” in the proposed Reliability Standard ensures the
standard is technologically agnostic, allowing for future changes in technology and advances in
communication to be employed without requiring a change to the Reliability Standard.
Lastly, the proposed Reliability Standard expands the applicability of the Reliability
Standard to cover Distribution Providers and Generator Operators. These functional entities are
now required to have an Interpersonal Communication capability with the listed entities in
Requirements R7 and R8, respectively. This is directly responsive to directives in Order No.
693, as discussed below.
4.
Proposed COM-001-2 Satisfies the Commission’s Directives
In Order No. 693, the Commission issued three directives to NERC to modify certain
aspects of the currently effective COM-001-1 Reliability Standard. Each is explained in turn,
along with how the proposed Reliability Standard satisfies the directive.
The Commission reaffirmed its position taken in the Notice of Proposed Rulemaking that
“Generator Operators” and “Distribution Providers” should be included as applicable entities in
COM-001-1 to ensure there is no reliability gap during normal and emergency operations.39 The
Commission argued that during a blackstart when normal communications may be disrupted, it is
39
Id. at PP 487-93.
20
essential that the Transmission Operator, Balancing Authority and Reliability Coordinator
maintain communications with their Distribution Providers and Generator Operators. In
developing requirements for these newly applicable entities, the Commission noted that the
revised Reliability Standard could establish an appropriate range of requirements for
telecommunication facilities that reflect their respective roles on Reliable Operation of the BulkPower System.
The Commission also issued additional directives to revise COM-001-140 to: (i) identify
specific requirements for telecommunications facilities for use in normal and emergency
conditions that reflect the roles of the applicable entities and their impact on Reliable Operation;
and (ii) include adequate flexibility for compliance with the Reliability Standard, adoption of
new technologies and cost-effective solutions.41
Proposed COM-001-2 meets all three of the Commission’s directives issued in Order No.
693. First, NERC has included “Generator Operators” and “Distribution Providers” as covered
applicable entities pursuant to the Commission’s directive.
Second, proposed COM-001-2 meets the Commission’s directive to “identify specific
requirements for telecommunications facilities for use in normal and emergency conditions that
reflect the roles of the applicable entities and their impact on Reliable Operation.” The proposed
Reliability Standard sets requirements to have “Interpersonal Communication” capability and
“Alternative Interpersonal Communication” capability, where noted in the requirements, without
limitation on the operating condition for each of the applicable entities (see Requirements R1R8). By setting parameters for the types of communications capabilities and setting
requirements for maintaining capabilities between certain functional entities, the proposed
40
41
Id. at PP 502-04.
Id. at P 508 (summarizing Commission directives on COM-001-1).
21
Reliability Standard sets a clear baseline for communications capability during all operating
conditions. In addition, the proposed Reliability Standard includes requirements for notifying
other functional entities of the loss or failure of certain communications capabilities, further
ensuring that entities are aware of the communications capabilities of other functional entities.
Lastly, the proposed Reliability Standard uses terminology that has sufficient flexibility
for entities to adopt new technologies and cost-effective solutions. The requirements purposely
use the word “capability” in a general sense in order to remain agnostic on the specific
technology an entity must use, allowing opportunity for the adoption of new technology and
cost-effective solutions that may become available for use in the future.
5.
Revisions to Reliability Standard COM-001-1.1
Exhibit C to this petition contains an “Implementation Plan and Mapping Document” for
proposed COM-001-2 that describes the associated retirement of currently effective COM-0011.1 and provides a detailed mapping of how the requirements in COM-001-1.1 translate into
proposed COM-001-2. In summary, proposed COM-001-2 will retire all Requirements of COM001-1.1 upon proposed COM-001-2 becoming effective with the exception of Requirement R4.
Requirement R4 of COM-001-1.1 will be retired by proposed Reliability Standard COM-002-4
because this Requirement was referred to Project 2007-02 for inclusion in COM-003-1, which
addressed communications protocols. Of particular note in the Implementation Plan, the
standard drafting team concluded that Requirement R5 in COM-001-1.1 is redundant with EOP008-1, Requirement R1 and, therefore, has not been carried forward in proposed COM-001-2.
As a result, NERC proposes EOP-008-1, Requirement R1 for retirement.
22
Additionally, Requirement R6 of COM-001-1.1 is also being proposed for retirement,
which requires adherence to certain policies and requirements when using NERCnet.42
Specification of the types of tools to be employed and requirements for interfacing with these
tools are best handled by NERC internal policies. This approach preserves NERC’s ability to be
responsive to new technologies and improvements in security of the tool without having to
modify a Reliability Standard to do so. The development of tools should support registered
entities in meeting the intent of a Reliability Standard without creating a burden on acquisition of
specific technology or tools. NERC is currently transitioning NERCnet to industry. Industry
will take on the network infrastructure upgrade and future maintenance and enhancements.
This transition will be complete prior to the effective date of COM-001-2. Policies and
requirements for use of the new tool will be addressed internally by NERC as part of the new
program.
B.
Proposed Reliability Standard COM-002-4
1.
Purpose of Proposed Reliability Standard
Proposed Reliability Standard COM-002-4 revises the currently effective COM-002-2
Reliability Standard and the Board-adopted COM-002-3 Reliability Standard.43 The purpose of
proposed Reliability Standard COM-002-4 is to improve communications for the issuance of
Operating Instructions with predefined communications protocols to reduce the possibility of
miscommunication that could lead to action or inaction harmful to the reliability of the Bulk
Electric System. The proposed Reliability Standard combines proposed Reliability Standard
42
See infra FN 21.
The Board-adopted COM-002-3 Reliability Standard is proposed for retirement in the Implementation Plan
because the proposed Reliability Standard has been combined with proposed COM-003-1 to create proposed COM002-4. COM-002-3 has not been submitted to the Commission for approval, therefore, the currently effective
version of COM-002 in the United States is COM-002-2.
43
23
COM-002-3 and the former draft COM-003-1 into a single standard that addresses
communications protocols for operating personnel in Emergency and non-emergency conditions.
2.
Standard Development History
The standard drafting team conducted eight comment and ballot periods in arriving at the
final industry-approved language in the proposed COM-002-4 Reliability Standard. Over that
time, the standard drafting team responded to comments and revised the draft Reliability
Standard based on the consensus view of the standard drafting team following each consideration
of comments. In addition to the required steps outlined in the Standards Development Process,
the standard drafting team conducted stakeholder outreach in order to arrive at a draft Reliability
Standard that meets the stated purpose of the Reliability Standard, addresses the Commission’s
directives, and represents consensus in industry, including:
•
a full-day “Communications in Operations” technical conference held February 1415, 2013 to gather industry input on a consensus communications standard approach;
•
a survey distributed to a sample of industry experts by the Director of Standards
Development and the Standards Committee Chair requesting feedback on the draft
standard in preparation for the eighth additional ballot; and
•
consultation on the use of the term “Reliability Directive” in the COM-002-4 standard
with the Project 2007-03 Real-time Transmission Operations standard drafting team
and the Project 2006-06 Reliability Coordination standard drafting team.
In addition to the outreach above, the standard drafting team received input from the
NERC Board of Trustees on two occasions. On August 15, the Board adopted a resolution,44
which requested input from NERC’s Reliability Issues Steering Committee (“RISC”), the
Independent Experts Review Panel, and NERC management to inform the Board and provide
44
See Draft Minutes of the Board of Trustees, August 15, 2013 at 3-4, available at
http://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/BOT0813m-draft-complete.pdf.
24
input into the standard development process. These inputs were provided to the standard
drafting team for its consideration and to the Operating Committee, with a request that the
Operating Committee provide its input to as well. Responses from RISC, the Independent
Experts Review Panel, NERC management, and the Operating Committee are included in
Exhibit O.
At its November 7, 2013 meeting, the Board of Trustees adopted a resolution for the
further development of the COM-003-1 Reliability Standard.45 The resolution provided
additional recommendations to the standard drafting team on the development of a subsequent
revised draft.
3.
Requirements, Technical Basis, and Defined Terms
Following posting six of the proposed COM-002-4 Reliability Standard, NERC staff
prepared a “strawman” draft that combined the COM-002-3 and draft COM-003-1 Reliability
Standards. The “strawman” provided a starting point for the standard drafting team to edit and
adjust as it deemed appropriate based on its own expertise and from the feedback industry
provided during the Standards Development Process.
In proposed COM-002-4, the same protocols are required to be used in connection with
the issuance of Operating Instructions for all operating conditions – i.e., non-emergency and
Emergency communications. However, the proposed Reliability Standard employs the phrase
“Operating Instruction during an Emergency” in certain Requirements (R5, R6, R7) to provide a
demarcation for what is subject to a zero-tolerance compliance approach and what is not. This
separation in the requirement structure is necessary to draft Violation Severity Levels to match
45
See Resolution for Agenda Item 8.i: Operating Personnel Communication Protocols, Nov. 7, 2013,
available at
http://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/Board%20COM%20Resolution
%2011.7.13%20v1%20AS%20APPROVED%20BY%20BOARD.pdf.
25
each compliance approach described in the Board’s resolution. Where “Operating Instruction
during an Emergency” is not used, an entity will be assessed under a compliance approach that
focuses on whether an entity meets the initial training Requirement (either R2 or R3) and
whether an entity performed the assessment and took corrective actions according to
Requirement R4.
An entity should expect its operating personnel that issue and receive Operating
Instructions to use the entity’s documented communication protocols for the issuance and receipt
of all Operating Instructions. An entity reinforces its use of the documented communication
protocols through training, assessing adherence by its operating personnel to the documented
communication protocols, and providing feedback to those operating personnel on their use of
the protocols. During Emergencies, operating personnel must use the documented
communication protocols for three-part communications without exception, since clear
communication is essential to providing swift and coordinated response to events that are
directly impacting the reliability of the Bulk Electric System.
a)
Definition of “Operating Instruction”
The current draft of COM-002-4 no longer includes the term “Reliability Directive,”
which was included in previous postings as a subset within the definition of “Operating
Instruction.”46 The proposed definition of “Operating Instruction” reads as follows:
46
On November 21, 2013, the Commission issued a Notice of Proposed Rulemaking, which proposes to
remand certain proposed TOP and IRO standards. Monitoring System Conditions- Transmission Operations
Reliability Standard Transmission Operations Reliability Standards Interconnection Reliability Operations and
Coordination Reliability Standards, NOPR, 145 FERC ¶ 61,158 (2013). The TOP/IRO NOPR is available at:
http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/NOPR_TOP_IRO_RM13-12_RM13-14_RM1315_20131121.pdf. The proposed remand includes the defined term “Reliability Directive.” FERC’s proposal to
remand the term “Reliability Directive” raised possible complications with the draft COM-002-4 Reliability
Standard, which used the proposed definition. The standard drafting team consulted on the use of the term
“Reliability Directive” in the COM-002-4 Reliability Standard with the Project 2007-03 Real-time Transmission
Operations and the Project 2006-06 Reliability Coordination Standard Drafting Teams to ask whether they believed
26
A command by operating personnel responsible for the Real-time
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 “command” as used in the definition refers to both oral and written commands by operating
personnel. The standard drafting team purposely did not modify the word “command” with
either “oral” or “written” in order to maintain its broader meaning. Instead, in the requirements
of COM-002-4, the standard drafting team has specified “oral” or “written” as needed to define
which types of Operating Instructions are covered by the requirement. The definition also
includes a clarifying note in parentheses that general discussions are not considered Operating
Instructions. This clarification was requested by and supported by industry for inclusion in the
definition itself.
b)
Applicability
In addition to Balancing Authorities, Reliability Coordinators, and Transmission
Operators, proposed COM-002-4 applies to Distribution Providers and Generator Operators.
The standard drafting team added these entities in the Applicability section because they can be
and in many cases are the recipients of Operating Instructions. The standard drafting team
determined that not including these entities would leave a gap in a communications standard that
addresses operating personnel. The addition of Distribution Providers as an applicable entity also
removal of the term would cause concerns. Both teams agreed that the COM-002-4 standard did not need to require
a specific protocol to identify “Reliability Directives” as such and that the definition of “Operating Instruction”
could be used absent the term Reliability Directive in COM-002-4 to set the protocols. This would leave the TOP
and IRO standard drafting teams the flexibility to address the issues surrounding the term “Reliability Directive” in
response to the FERC TOP/IRO NOPR.
27
responds to FERC’s directive in Order No. 693 to add them as applicable entities to the
communications standard.
Recognizing that Generator Operators and Distribution Providers typically only receive
Operating Instructions, the standard drafting team proposed that only Requirements R3 and R6
apply to these entities. Under proposed COM-002-4, Distribution Providers and Generator
Operators are required to: (i) train operators prior to receiving an Operating Instruction; and (ii)
use three part communication when receiving an Operating Instruction during an Emergency.
The Measures for the requirements related to these applicable entities show that Distribution
Providers and Generator Operators can demonstrate compliance for use of three-part
communication when receiving an Operating Instruction during an Emergency by providing an
attestation from the issuer of the Operating Instruction (i.e., a voice recording is not required). If
a Distribution Provider or Generator Operator never receives an Operating Instruction, the
requirements in proposed COM-002-4 would not apply. In both Requirements R3 and R6,
qualifying language triggering performance based on the “receipt” of an Operating Instruction is
included. This construct makes certain that appropriate entities are trained and able to use threepart communication for reliability purposes.
c)
Requirements in Proposed COM-002-4
Proposed COM-002-4 has seven requirements that require certain entities to develop
predefined communications protocols for the issuance of Operating Instructions. Each
requirement and its Parts are discussed in detail below along with the technical basis for the
inclusion of the requirement in the proposed Reliability Standard.
Requirement R1
28
Requirement R1 requires entities that can both issue and receive Operating Instructions to
have documented communications protocols that include a minimum set of elements, outlined in
Parts 1.1 through 1.6 of the Requirement. Because Operating Instructions affect Facilities and
Elements of the Bulk Electric System, the communication of those Operating Instructions must
be understood by all involved parties, especially when those communications occur between
functional entities. An EPRI study reviewed nearly 400 switching mishaps by electric utilities
and found that roughly 19% of errors (generally classified as loss of load, breach of safety, or
equipment damage) were due to communication failures.47 This was nearly identical to another
study of dispatchers from 18 utilities that found that 18% of the operators’ errors were due to
communication problems.48 The necessary protocols include the use of the English language
unless agreed to otherwise (except for internal operations), protocols for use of a written or oral
single-party to multiple-party burst Operating Instruction, three-part communications (including
a protocol for taking an alternate action if a response is not received or if the Operating
Instruction was not understood by the receiver), specification of instances that require time
identification, and specification of nomenclature for Transmission interface Elements.
Requirement R1 provides consistency among communications protocols and promotes
effective communications, while also allowing flexibility for entities to develop additional
communications protocols based on its own operating environment. The inclusion of the
elements in Parts 1.1 through 1.6 are necessary to improve communications protocols and drive
uniformity.
47
Beare, A., Taylor, J. Field Operation Power Switching Safety, WO2944-10, Electric Power Research
Institute.
48
Bilke, T., Cause and prevention of human error in electric utility operations, Colorado State University,
1998.
29
The term “documented communication protocols” in R1 refers to a set of required
protocols specific to the applicable entity and the entities with whom they must communicate.
An entity should include as much detail as it believes necessary in its documented
communication protocols,49 but the documented communication protocols must address all of the
applicable Parts of Requirement R1. Where an entity does not already have a set of documented
communications protocols that meet the Parts of Requirement R1, the entity must develop the
necessary communications protocols. Entities may also adopt the documented protocols of
another entity as its own communications protocols, but the entity must maintain its own set of
documented communications protocols to meet Requirement R1. Each part of Requirement R1
is discussed below:
1.1.
Require its operating personnel that issue and receive an oral or written
Operating Instruction to use the English language, unless agreed to otherwise. An
alternate language may be used for internal operations.
Use of English language has been carried forward from COM-001-1.1, Requirement R4
as an essential protocol. As noted above, retirement of this requirement in COM-001-1.1 was
specifically referred to Project 2007-02. Part 1.1 continues to permit the issuer and receiver to
use an agreed to alternate language. This has been retained since use of an alternate language, on
a case-by-case basis, may serve to better facilitate effective communications where the use of
English language may create additional opportunities for miscommunications. Part 1.1 requires
the use of English language (unless agreed to otherwise) when issuing oral or written50 Operating
49
On September 19, 2012, the NERC Operating Committee issued a Reliability Guideline entitled: “System
Operator Verbal Communications – Current Industry Practices.” As stated on page one, the purpose of the
Reliability Guideline “. . . is to document and share current verbal Bulk Electric System communications practices
and procedures from across the industry that have been found to enhance the effectiveness of system operator
communications programs.” This guideline serves as an additional source of information on best practices that
entities can draw on in creating the documented communications protocols. The guideline is available at:
http://www.nerc.com/comm/OC/Reliability%20Guideline%20DL/Reliability_Guideline_Final_2012.pdf.
50
An example of a written Operating Instruction is a switching order.
30
Instructions. This creates a standard language (either English or an agreed upon alternate
language) for use when issuing commands that could change or preserve the state, status, output,
or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. Part
1.1 also clarifies that an alternate language can be used internally within the organization. The
wording of the Part has been modified slightly from the language in COM-001-1.1, Requirement
R4 to incorporate the term “Operating Instruction,” which defines the communications that
require the use of the documented communications protocols.
1.2. Require its operating personnel that issue an oral two-party, person-to-person
Operating Instruction to take one of the following actions:
•
•
•
Confirm the receiver’s response if the repeated information is correct.
Reissue the Operating Instruction if the repeated information is incorrect, if the
receiver does not issue a response, or if requested by the receiver.
Take an alternative if a response is not received or if the Operating Instruction
was not understood by the receiver.
1.3.
Require the receiver of an oral two-party, person-to-person Operating Instruction
to take one of the following actions:
•
•
Repeat the Operating Instruction and wait for confirmation from the issuer that
the repetition was correct.
Request that the issuer reissue the Operating Instruction.
Part 1.2 requires communications protocols for the use of three-part communications for
oral two-party, person-to-person Operating Instructions by the issuer. Part 1.3 requires
communications protocols for the use of three-part communications for oral two-party, personto-person Operating Instructions by the receiver. This carries forward the requirement to use
three-part communications in COM-002-2 and COM-002-3 and also adds an option in Part 1.2
for the issuer to take an alternative action to resolve the issue if the receiver does not respond or
understand the Operating Instruction. The addition of this third bullet, which is not included in
31
COM-002-2, serves to clarify in the requirement language itself that the issuing entity can take
alternate action in lieu of reissuance, if necessary.
Three-part communication reduces the opportunity for confusion and misunderstanding
when issuing and receiving Operating Instructions during all operating conditions. Because
three-part communication is included as a protocol for both non-emergency conditions and
Emergency conditions, there will be no mental “transition” between protocols when operating
conditions shift from non-emergency to Emergency. The documented communication protocols
for the operating personnel will remain the same during transitions through all operating
conditions. Further, the formal requirement for three-part communication in an entity’s
documented communications protocols will create a heightened sense of awareness in operating
personnel that the task they are about to execute is critical, and recognize the risk to the reliable
operation of the Bulk Electric System is increased if the communication is misunderstood.
1.4.
Require its operating personnel that issue a written or oral single-party to
multiple-party burst Operating Instruction to confirm or verify that the Operating
Instruction was received by at least one receiver of the Operating Instruction.
This Part requires specific communications protocols for the issuance of an Operating
Instruction using a one-way burst messaging system. One-way burst messaging systems are used
to issue Operating Instructions to many entities at once. Because the use of three-part
communications is not practical when utilizing this type of communication, a separate protocol
was added to the proposed Reliability Standard. During the Standards Development Process,
many entities expressed concern that if one-way burst messaging systems were not addressed, it
would imply that three part communication would be required for all participants in the burst
message.
1.5. Specify the instances that require time identification when issuing an oral or
written Operating Instruction and the format for that time identification.
32
This Part requires entities to identify the instances where time identification is required
when issuing an oral or written Operating Instruction. Clarifying time and time zone (where
necessary) contributes to reducing misunderstandings and reduces the risk of a grave error during
BES operations, especially when communicating across time zones or specifying an action that
will take place at a future time. The Part forces entities to name the instances in the documented
communications protocols themselves if time identification is used. The standard drafting team
chose this method of identification in lieu of requiring time identification to maintain flexibility
for the entity in designing its communications protocols, but also providing clarity in the
documented communications protocols where it is used.
1.6.
Specify the nomenclature for Transmission interface Elements and Transmission
interface Facilities when issuing an oral or written Operating Instruction.
Similarly to Part 1.5, Part 1.6 does not prescriptively require the use of nomenclature for
Transmission interface Elements and Transmission interface Facilities when issuing an oral or
written Operating Instruction. The standard drafting team opted to require entities to identify the
nomenclature, if it is used. This Part limits the scope to only Transmission interface Elements or
Transmission interface Facilities (e.g., tie lines and tie substations). This ensures that
communicating parties are readily familiar with each other’s interface Elements and Facilities,
eliminating hesitation and confusion when referring to equipment for the Operating Instruction.
This shortens response time and improves situational awareness. It also permits entities to
jointly develop the nomenclature for their interface.
Requirements R2 and R3
Requirement R2 requires each Balancing Authority, Reliability Coordinator, and
Transmission Operator to conduct initial training for each of their operating personnel
33
responsible for the Real-time operation of the Bulk Electric System on the entity’s documented
communication protocols.
Requirement R3 requires Distribution Providers and Generator Operators to conduct
initial training on three part communication for each of their operating personnel who can
receive an oral two-party, person-to-person Operating Instruction prior to that individual operator
receiving an oral two-party, person-to-person Operating Instruction. Distribution Providers and
Generator Operators would have to train their operating personnel prior to placing them in a
position to receive an oral two-party, person-to-person Operating Instruction. Operating
Personnel that would never be in a position to receive an oral two-party, person-to-person
Operating Instruction, therefore, would not need initial training unless their circumstance
changes.
Initial training is included in proposed COM-002-4 in response to the NERC Board of
Trustees resolution, which directs that a training requirement be included. Additionally,
requiring entities that issue and or receive Operating Instructions to conduct initial training with
their operating personnel will ensure that all applicable operators will be trained in three-part
communication. This training will reduce the possibility of a miscommunication, which could
eventually lead to action or inaction harmful to the reliability of the Bulk Electric System.
Ongoing training beyond initial training would fall under an entities’ training program in PER005 or could be separately listed as a type of corrective action under Requirement R4. Training
is also mentioned by Commission staff in its Preliminary Assessment as an important aspect to
effective communications.51
Requirement R4
51
Preliminary Assessment at 43 (citing Blackout Report at 161 which provides that lack of situational
awareness can result from, among other things, inadequate operator training).
34
Requirement R4 requires Balancing Authorities, Reliability Coordinators, and
Transmission Operators to, at least once every 12 months, assess adherence by its operating
personnel to the documented communication protocols in Requirement R1 and to provide
feedback to its operating personnel on their performance. This also includes any corrective
action taken, as appropriate, to address deviations from the documented protocols. Requirement
R4 also requires the aforementioned entities to assess the effectiveness of their documented
communications protocols and make changes, as necessary, to improve the effectiveness of the
protocols. An entity may determine that corrective action beyond identification of the misuse of
the documented communications protocols to the operating personnel is not necessary, therefore,
the phrase “as appropriate” is included in the Requirement R4 language to indicate that whether
to take additional corrective action is determined by the entity and not dictated by the
Requirement for all instances of a misuse of a documented communication protocol. In almost
all cases found by an entity, NERC expects that an entity will have some form of corrective
action such as ongoing scheduled training.
Most entities currently engage in some type of assessment activity for their operating
personnel and provide operators with performance feedback on their adherence to the entity’s
documented protocols. Doing so, provides entities an opportunity to evaluate the performance of
their operating personnel and take corrective actions where necessary, which could prevent a
miscommunication from occurring and thus possibly prevent an event which could be harmful to
the reliability of the Bulk Electric System.
The associated Measure M4 for Requirement R4 lists the types of evidence that an entity
can provide to demonstrate compliance and explains when an entity should show the corrective
actions taken. Of particular interest is any corrective action taken where the miscommunication
35
is the sole or partial cause of an Emergency and the entity has opted to take a corrective action.
While the Measure lists out this particular set of circumstances to highlight the importance, the
Measure does not modify the Requirement to require corrective action.
Requirement R4 is the primary mechanism for implementation of the documented
communication protocols in proposed COM-002-4 for non-emergency conditions. In order to
meet its obligations under Requirement R4, an entity must be actively employing its documented
communications protocols. However, the requirement also extends to assessing the use of
communications protocols during Emergency communications. Specifically, this requirement
compels entities to assess the adherence of its operating personnel to the pre-defined
communication protocols, provide feedback to its operating personnel based on their
performance, and implement corrective action to address deviations from those protocols or
general ineffectiveness where necessary. Requirement R4 also aims to ensure that the
documented protocol remains current and effective to address potential reliability issues that
could be caused by non-inclusion of a communication protocol not otherwise required by
Requirement R1.
The creation of an assessment obligation and a protocol effectiveness review process that
arises at least once every twelve (12) months provides a short evaluation and correction cycle for
entities. By providing feedback to operators on a regular basis, these entities can evaluate
performance and take necessary corrective action in a timely manner. Specification that the
review must occur “at least once every twelve (12) months” also does not preclude entities from
employing processes that provide feedback in an even shorter timeframe or multiple times per
year as part of their process design.
36
The language of the requirement clearly and explicitly delineates the obligations and
expectations entities must meet. Requirement R4 requires that each entity maintain a successful
program and measure its own compliance with its documented communications protocols.
Requirement R4 intentionally does not specify a specific type of review to execute or mandate
that corrective actions be taken. Entities are better equipped to design an appropriate program to
meet their own operating environment and determine whether a corrective action is necessary.
Because almost all entities have these types of programs in place today, this approach also
provides an efficient means of establishing an assessment program by building on the programs
currently in use. The primary purpose of Requirement R4 is to provide assurance that an entity
is using its documented communications protocols, engaging its operators, and periodically
reviewing its communications for improvement. The program required in Requirement R4
requires applicable entities to conduct retrospective review of their communications practices
based on predefined documented communications protocols through an assessment design of
their choosing and requires corrective actions be taken if the entity deems a corrective action
necessary. As a result, Requirement R4 contains clear, unambiguous directions regarding the
obligations placed on the entity.
The assessment process embodied in Requirement R4 has also been used in other
Commission-approved NERC Reliability Standards. For example, Commission-approved
Reliability Standard FAC-003-3 requires applicable entities to have in place “documented
maintenance strategies or procedures or processes or specifications it uses to prevent the
encroachment of vegetation into the MVCD of its applicable lines.” Entities are required to
identify “the existence of a vegetation condition that is likely to cause a Fault at any moment,”
and to remedy the problematic conditions. Requirement R5 states “… the applicable
37
Transmission Owner or applicable Generator Owner shall take corrective action to ensure
continued vegetation management to prevent encroachments.” This risk-based requirement
obligates applicable entities to create a current “documented maintenance strategy” to prevent
vegetation encroachment, identify certain constraints, assess the possibility of a potential
encroachment based on the documented strategy, and take necessary corrective action to ensure
continued vegetation management.
In addition, Commission-approved Reliability Standard PRC-005-2 requires that
applicable entities “establish a Protection System Maintenance Program (“PSMP”) for its
Protection Systems,” and then implement and follow these PSMPs to achieve ideal intended
performance. Applicable entities should subsequently “demonstrate efforts to correct identified
Unresolved Maintenance Issues”. These standards also require applicable entities to develop a
tailored baseline target for performance and retroactively measure compliance based on
adherence to this predefined standard.
Additionally, Commission-approved Reliability Standard PRC-006-1 requires applicable
entities to document certain criteria regarding the creation of islands and develop an
underfrequency load-shedding (“UFLS”) program to arrest declining frequency, assist recovery
of frequency following underfrequency events, and provide last resort system preservation
measures. The Reliability Standard requires entities to conduct various assessments to determine
conformity with the UFLS program created pursuant to Requirement R3 of that Reliability
Standard. While a corrective action element is not included in the Reliability Standard language
itself, NERC did clarify during regulatory approval, to the satisfaction of the Commission, that
the language of PRC-006-1 anticipated corrective action.
Requirements R5 and R6
38
Requirement R5 requires entities that issue oral two-party, person-to-person Operating
Instructions during an Emergency, excluding written or oral single-party to multiple-party burst
Operating Instructions, to use three-part communication or take an alternate action if the receiver
does not respond or if the receiver did not understand the Operating Instruction. The language of
Requirement R5 specifically excludes written or oral single-party to multiple-party burst
Operating Instructions to make clear that three-part communication is not required when issuing
Operating Instructions in this manner. Requirement R5 applies to each Balancing Authority,
Reliability Coordinator, and Transmission Operator since these are the entities that would be in a
position to issue oral two-party, person-to-person Operating Instructions during an Emergency.
Requirement R6 requires entities that receive an oral two-party, person-to-person
Operating Instruction during an Emergency, excluding written or oral single-party to multipleparty burst Operating Instructions, to repeat (not necessarily verbatim) the Operating Instruction
and receive confirmation from the issuer that the response was correct, or request that the issuer
reissue the Operating Instruction. Requirement R6 includes the same clarifying language as
Requirement R5 for the exclusion of single-party to multiple-party burst Operating Instructions.
Requirement R6 applies to each Balancing Authority, Distribution Provider, Generator Operator,
and Transmission Operator since these are the entities that would be in a position to receive oral
two-party, person-to-person Operating Instructions during an Emergency.
The use of three-part communication when issuing and receiving Operating Instructions
is always important because a miscommunication could create an Emergency. However, the use
of three-part communication is critically important if an Emergency condition already exists, as
further action or inaction could increase the harmful effects to the Bulk Electric System. Clear
39
communication is essential to providing swift and coordinated response to events that are
directly impacting the reliability of the Bulk Electric System.
Requirement R7
Requirement R7 requires that when a Balancing Authority, Reliability Coordinator, or
Transmission Operator issues a written or oral single-party to multiple-party burst Operating
Instruction during an Emergency, it must confirm or verify that at least one receiver of the
Operating Instruction received the Operating Instruction. Because written or oral single-party to
multiple-party burst Operating Instruction during an Emergency are excluded from Requirements
R5 and R6, this separate Requirement is necessary to specify the performance an entity must
meet to demonstrate clear communication for the use of written or oral single-party to multipleparty burst Operating Instructions during an Emergency. This prevents a gap in the means used
to issue an Operating Instruction during an Emergency. This requirement is necessary because
without confirmation from at least one receiver, the issuer has no way of confirming if the
Operating Instruction was transmitted and received by any of the recipients. Therefore, the
issuer cannot know whether to resend the Operating Instruction, wait for the recipient to take an
action, or take an alternate action because the recipient cannot perform the action. As a best
practice, an entity can opt to confirm receipt from more than one recipient, which is why the
requirement states “at least one.”
4.
Improvements Reflected in COM-002-4
Proposed COM-002-4 includes a number of improvements over the currently effective
Reliability Standard COM-002-2. These include: (i) removing the ambiguity surrounding the
meaning of “directive” in COM-002-2; (ii) specifying specific minimum protocols that must be
included and used by all applicable entities; (iii) mandating initial training for operating
40
personnel; and (iv) adding a process for entities to assess adherence to the documented
communication protocols and take corrective action.
First, proposed COM-002-4 replaces the term “directive” in COM-002-2 with a new
defined term “Operating Instruction.” Use of the defined term clarifies the types of commands
covered by the proposed Reliability Standard, which now includes all commends “by operating
personnel responsible for the Real-time 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.” It was not clear whether the term “directive” referred to
either non-emergency and emergency directives, or just emergency directives. This ambiguity
was the subject of the interpretation request to COM-002-2 adopted by the Board of Trustees in
2012.52
Second, proposed COM-002-4 adds additional mandatory communications protocols in
Requirement R1 beyond the use of three-part communication covered by COM-002-2 and the
use of English language found in COM-001-1.1, Requirement R4. The proposed Reliability
Standard adds protocols for: the issuance of a written or oral single-party to multiple-party burst
Operating Instruction; specification of the instances that require time identification when issuing
an oral or written Operating Instruction and the format for that time identification; and
52
On October 1, 2009, a clarification was requested by the ISO-RTO Council of Requirement R2 of COM002-2, specifically asking whether “directives” are limited to actions requested during actual and anticipated
emergency operating conditions, or whether routine operating instructions are also considered “directives.” The
interpretation of Reliability Standard COM-002-2, approved by the NERC Board of Trustees on February 9, 2012,
clarifies that COM-002-2 R2 does not specify the conditions under which a directive is issued, nor does it define
directive. It only provides that the requirements be followed when a directive is issued to address a real-time
emergency. Routine operating instructions during normal operations would not require the communications
protocols for repeat backs as specified in R2. The NERC Board of Trustees rescinded approval of the interpretation
in conjunction with its adoption and successful implementation of proposed COM-002-4 since the proposed
Reliability Standard no longer uses the lower case term “directive.” See Agenda Item 8c of the May 7, 2014 Board
of Trustees Meeting, available at
http://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/board_agenda_package_May_20
14.pdf.
41
specification of the nomenclature for Transmission interface Elements and Transmission
interface Facilities when issuing an oral or written Operating Instruction. Proposed COM-002-4
also includes specific communications protocols for the entity receiving an Operating
Instruction, which is not present in COM-002-2. COM-002-2, by contrast, places the
responsibility for ensuring proper three-part communication on the issuing entity only.
Third, for the first time, the COM-002 Reliability Standard will include requirements to
provide initial training to operating personnel who issue and receive Operating Instructions.
While many entities reported during the Standards Development Process that they already
conduct training of their operating personnel, the inclusion of these requirements codifies the
expectation that all operating personnel be trained on the documented communications protocols
prior to being placed in a position to issue or receive an Operating Instruction. As FERC staff
noted in its Preliminary Assessment and as reflected in the Blackout Report, lack of situational
awareness can result from, among other things, inadequate operator training.53
Finally, the proposed COM-002-4 Reliability Standard adds a requirement for entities to
assess adherence to the documented communication protocols and take corrective action. This
aspect of the proposed Reliability Standard codifies good operating practice to review operator
communications and provide feedback to the operating personnel. The requirement will also
require entities to assess the effectiveness of their documented communications protocols and
determine if additional protocols should be specified based on the observed use of the protocols
in its operating environment. Such a requirement is not present in the prior version of the COM002 Reliability Standard.
5.
53
Proposed COM-002-4 Satisfies the Commission’s Directives
See Preliminary Assessment at 43 (citing Blackout Report at 161).
42
In Order Nos. 693, the Commission issued directives to NERC to modify certain aspects
of COM-002-2. Exhibit J of this Petition provides a list of the directives and an explanation of
the standard drafting team’s consideration of each directive. In short, the Commission directed
NERC to include Distribution Providers as an applicable entity in the Reliability Standard. The
Commission stated, “during both normal and emergency operations, it is essential that the
transmission operator, balancing authority and reliability coordinator have communications with
distribution providers.”
Second, the Commission directed NERC to include a requirement for the Reliability
Coordinator to assess and approve actions that have impacts beyond the area views of
transmission operators or balancing authorities, including how to determine whether an action
needs to be assessed by the reliability coordinator. This directive was addressed outside of the
revisions to COM-002-2. It was addressed by modifications to IRO-005 and has been reassigned
to Project 2014-03.
Third, the Commission directed NERC to either modify the COM-002-2 Reliability
Standard to require “tightened communications protocols, especially for communications during
alerts and emergencies” or develop a new Reliability Standard to meet Blackout Report
Recommendation No. 26. The following is a discussion of the outstanding directives addressed
by proposed COM-002-4:
Addition of Distribution Providers (Order No. 693, P 512 and 540 (Part 1)): As noted
above in the discussion of Requirements R3 and R6 and the Applicability section, Distribution
Providers have been added to the coverage of proposed COM-002-4. Coverage within the
requirements has been limited to their position as “receivers” of Operating Instructions.
43
Tightened Communication Protocols (Order No. 693, P 531, 534, 535, 540 (Part 3)):
Proposed COM-002-4 satisfies the Commission’s directive regarding establishing “tightened
communication protocols” through the various improvements listed in the section above.
Proposed COM-002-4 improves communications protocols for the issuance of Operating
Instructions in order to reduce the possibility of miscommunication that could lead to action or
inaction harmful to the reliability of the Bulk Electric System. The proposed Reliability Standard
adds clarity to the scope of covered commands with the use of the new defined term “Operating
Instruction. Proposed COM-002-4 also includes additional mandatory protocols that establish
communication uniformity as much as practical on a continent-wide basis, while still
maintaining flexibility for entities to employ additional protocols based on its own operating
environment. The proposed Reliability Standard also “tightens communications protocols” by
employing clear, zero-tolerance approaches for miscommunications of Operating Instructions
issued during Emergencies and by mandating an assessment process aimed at reducing the
number of repeat misuses of communication protocols by operating personnel.
C.
Enforceability of Proposed Reliability Standards
The proposed Reliability Standards, COM-001-2 and COM-002-4 include Measures that
support each requirement to help ensure that the requirements will be enforced in a clear,
consistent, non-preferential manner and without prejudice to any party. The proposed Reliability
Standards also include VRFs and VSLs for each requirement. The VRFs and VSLs for the
proposed Reliability Standards comport with NERC and Commission guidelines related to their
assignment. A detailed analysis of the assignment of VRFs, the VSLs for proposed COM-001-2
and COM-002-4 are included as Exhibit K and Exhibit L.
VI.
CONCLUSION
44
For the reasons set forth above, NERC respectfully requests that the Commission:
•
approve the proposed Reliability Standards and other associated elements included in
Exhibits A and B;
•
the new definitions, as noted herein;
•
the VRFs and VSLs (Exhibits A, B, K, and L);
•
approve the Implementation Plans included in Exhibits C and D; and
•
approve the retirement of the currently effective Reliability Standards COM-001-1.1,
EOP-008-1 (Requirement R1), and COM-002-2, as proposed in the Implementation
Plans.
Respectfully submitted,
/s/ William H. Edwards
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
William H. Edwards
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
Date: May 14, 2014
45
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing document upon all parties
listed on the official service list compiled by the Secretary in the RM06-16-000 proceeding.
Dated at Washington, D.C. this 14th day of May, 2014.
/s/ William H. Edwards
William H. Edwards
Counsel for North American Electric
Reliability Corporation
| File Type | application/pdf |
| File Title | Microsoft Word - COM Petition Final |
| Author | baughanc |
| File Modified | 2015-05-07 |
| File Created | 2014-05-14 |