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

2. Agenda
Project – Background
COM Requirements
Implementation Plan
Compliance
VSL/VRF by Requirement
RSAW Notes
Next Steps

3. 2003 Blackout Report Recommendation 26
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 and COM 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 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. Applies to Distribution Providers and Generator Operators
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.
Explain why DP and GOP are not in R5

9. Prerequisite Approval:
Implementation Plan
Approval:
COM 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. Types of Evidence Entities may provide
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 Requirement1
Low
Low to Severe 2
Moderate to Severe 3
High
High to Severe 4 5
Severe

12. RSAW for the two implementation Requirements R3 and R4:
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