COM-002-4 Operating
Personnel Communications
Protocols
Howard Gugel, Director of Standards Development, NERC
October 30, 2013
Agenda
• Project 2007-02 – Background
• COM-002-4 Requirements
• Implementation Plan
• Compliance
• VSL/VRF by Requirement
• RSAW Notes
• Next Steps
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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
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Background
• Standards Oversight and Technology Recommendation to
Board
• Standards Committee Waiver
• Development of COM-002-4 by Standard Drafting Team
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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.
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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.
o
o
o
o
o
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
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COM-002-4: R2
• Applies to Distribution Providers and Generator Operators
• Requires minimum set of protocols that must be included in
documented communications protocols.
o Three part communications
o Use of English language
o All call protocols
• These entities included to require three part participation for
receivers of Operating Instructions
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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.
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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
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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
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VRF/VSL Range by Requirement
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Requirement
VRF
VSL Range
1
Low
Low to Severe
2
Low
Moderate to Severe
3
High
High to Severe
4
High
High to Severe
5
Low
Severe
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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.
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Next Steps
• Oct 25th -Nov 4th : Ballot and Non-binding Poll
• Nov 7th : NERC Board of Trustees Meeting
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