COM-002-4 Operating Personnel Communications Protocols

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

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

3. Overview • 2003 Blackout Report Recommendation 26 • Tighten communications protocols, especially for communications during alerts and emergencies • FERC Order 693 directives on COM-002 • Add Distribution Providers • Require the Electric Reliability Organization (ERO) to establish tightened communication protocols, especially for communications during alerts and emergencies • COM-002-3 and COM-003-1 development • NERC Board of Trustees request for input from RISC, IERP and NERC Management

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

5. COM-002-4: Scope of Communications • Operating Instruction – A command by operating personnel responsible for the Real-time generation control and operation of the interconnected Bulk Electric System to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. A discussion of general information and of potential options or alternatives to resolve Bulk Electric System operating concerns is not a command and is not considered an Operating Instruction. A Reliability Directive is one type of an Operating Instruction.

6. COM-002-4: R1 • Applies to Balancing Authorities, Reliability Coordinators, and Transmission Operators • Requires minimum set of protocols that must be included in documented communications protocols. • Three part communications • Use of English language • Clarification for all call protocols • Instances where alpha-numeric and time designations are required • Nomenclature for interface Elements and Facilities • Allows entities the flexibility to specify additional protocols deemed necessary, but promotes uniformity in protocols. • Entities can draw on Operating Committee Guideline on communications for additional protocols

7. COM-002-4: R2 • Applies to Distribution Providers and Generator Operators • Requires minimum set of protocols that must be included in documented communications protocols. • Three part communications • Use of English language • All call protocols • These entities included to require three part participation for receivers of Operating Instructions

8. COM-002-4: R3, R4, R5 • Requirements R3 and R4 require entities implement the documented communications protocols. • Requirement 5 requires BAs, RCs, and TOPs to implement a method to evaluate their communications protocols established in accordance with R1.

9. Implementation Plan • Approval: • COM-002-4-Operating Personnel Communications Protocols • Definition of Operating Instruction as well as addition to NERC Glossary of Terms • Prerequisite Approval: • Approval of definition of Reliability Directive as well as addition to NERC Glossary of Terms • Retirements: • COM‐001‐1.1 Requirement R4 – Telecommunications  • COM‐002‐2 – Communication and Coordination  • COM‐002‐3 – Communication and Coordination

10. Compliance • Types of Evidence Entities may provide • Descriptions of Management Practices • Spreadsheets, memos, logs, independent review of operating personnel’s adherence to protocols and remediation of exceptions • Data Retention • One Calendar Year for evidence demonstrating compliance for each applicable requirement • Except for Voice Recordings, which are required to be kept for 90 days • Auditor focus is primarily on internal controls and their effectiveness, not the actual communications • Only if auditor cannot gain reasonable assurance communication protocols are not being followed, then recordings will be examined

11. VRF/VSL Range by Requirement

12. RSAW Notes • RSAW for the two implementation Requirements R3 and R4: • Entity must describe the management practices in place that provide the entity reasonable assurance that protocols established are being followed. • Evidence examples include spreadsheets, memos, or logs, evidencing periodic, independent review of operating personnel’s adherence to the protocols established in Requirement R1 and the remediation of noted exceptions. • Based on the assessment of risk and internal controls, audit approach could range from the exclusion of the implementation requirements from audit scope to the auditor reviewing a sample of voice recordings to ensure the protocols were followed. • Sampling is not a part of the audit process unless the auditor determines that the internal control is not properly designed or is ineffective.

13. Next Steps • Oct 25th -Nov 4th : Ballot and Non-binding Poll • Nov 7th : NERC Board of Trustees Meeting

14. Questions and Answers