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2015-07 Internal Communications Capabilities SAR

Description:

Start Date: 06/11/2015
End Date: 07/15/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

Venona Greaff, Oxy - Occidental Chemical, 7, 7/15/2015

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Oxy, Segment(s) 7, 5, 7/15/2015

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Other Answers

Kathy Caignon, On Behalf of: Kathy Caignon, , Segments 3

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The defined term used in the currently approved, pending effective standard,

INTERPERSONAL COMMUNICATION: (FERC Approved, NERC Glossary term, effective 10-01-2015)

Any medium that allows two or more individuals to interact, consult, or exchange information.”

is sufficient to address the commissions concerns by simply adding clarity to each of the requirements applicable entities.

FERC concerns:

  1. “Internal communications capabilities that could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.”

  2. “Address the adequacy of internal telecommunications (or other internal communication systems) that may have an adverse effect on reliability, even within a single functional entity, including:

(1) communications between geographically separate control centers within the same functional entity; and

(2) communications between a control center and field personnel.”

Examples to add:

R1.3 Reliability Coordinator control centers within the same functional entity.

R3.3 Transmission Operation control centers within the same functional entity.

R3.4 Transmission Operation control centers and field personnel.

R5.6 Balancing Authority control centers within the same functional entity.

R7.3 Distribution Provider control centers within the same functional entity.

R7.4 Distribution Provider control centers and field personnel.

I believe the simple changes outlined above and a "Technical Guide" as mentioned below would address all of the FERC concerns witout adding a significant complexity to complying with the standard.

 

Greg Froehling, On Behalf of: Rayburn Country Electric Cooperative, Inc., Texas RE, SPP RE, Segments 3, 4, 6

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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AEP believes that more specificity is needed in this SAR before we, along with industry, can provide meaningful and insightful feedback. At this point, there is no information regarding what possible changes NERC may consider making to either COM-001-2 or within a new standard. Though the SAR draws verbiage from FERC Order 808, the quotes are rather limited and do not provide specificity on FERC’s concerns, nor on how the project plans to address them. We recommend that additional detail be provided in the SAR by either the Standards Committee or eventual drafting team, and re-posted for industry comment.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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The NSRF agrees that this Project is to address the “adequacy of communication systems” and not how those systems are used.  COM-002-4 covers how entities use and apply systems.

First bullet: Ok

Second and fourth bullet:  The physical assets (Communication Systems) should be narrowly focused to those time periods when an Operating Instruction needs to be given. 

Third bullet:  Ok

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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We support the intent of the SAR, as the scope and the objectives both identify the concerns FERC has with internal communications, particularly within the same registered entity.  We do have interest in the amount of allowable flexibility that will be available for Alternative Interpersonal Communication capabilities with field personnel, as that could become administratively burdensome with the number of field personnel.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 7/9/2015

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 Does this FERC directive cover data transfer capabilities (data) as well as interpersonal communications (voice/email)?    

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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none

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Agree that the scope and objectives of the SAR address the directive in Order No. 808.

Molly Devine, On Behalf of: Molly Devine, , Segments 1

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Agree that the scope and objectives of the SAR address the directive in Order No. 808.

Molly Devine, 7/14/2015

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Molly Devine, 7/14/2015

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Molly Devine, 7/14/2015

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The STD should consider adding back in some of the requirements from COM-001-1 R1 and R2 . Under the R2 requirements the testing should only be on communication systems not used on a routine day to day operation. Communication systems used in day to day operations should be deemed,  Adequate internal communication systems. Only back-up systems should need to be tested  The STD will have to define Field Personal when addressing communication systems between control center personal and field personal. On call/call out procedures and cell phones may need to be addressed for field personal communications.

 

Dean E Fox

Consumers Energy

Supply Operations Training/Compliance Supervisor

517-788-1998

Lance Bean, On Behalf of: CMS Energy - Consumers Energy Company, RF, Segments 3, 4, 5

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We generally agree with the proposed scope and objectives of the SAR, but reserve judgment on the specific changes to the existing COM-001 standard or the proposed requirements in a new standard.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We generally agree with the proposed scope and objectives of the SAR, but reserve judgment on the specific changes to the existing COM-001 standard or the proposed requirements in a new standard.

Leonard Kula, Independent Electricity System Operator, 2, 7/14/2015

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We generally agree with the proposed scope and objectives of the SAR, but reserve judgment on the specific changes to the existing COM-001 standard or the proposed requirements in a new standard.

Mark Wilson, On Behalf of: Independent Electricity System Operator - NPCC - Segments NA - Not Applicable

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ERCOT supports the comments submitted by the ISO/RTO Council Standards Review Committee.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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ERCOT supports the comments submitted by the ISO/RTO Council Standards Review Committee.

christina bigelow, 7/14/2015

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COM-001-2 currently addresses communication infrastructure and capabilities between discrete functional roles (RC, TOP, BA, GOP, DP).  Bullets 1 and 2 of the project scope identify either a geographic location or specific personnel that must be defined when evaluating the adequacy of intra-functional role communication paths.  This will add some ambiguity and requires registered entity discretion when identifying the initiator and recipient of the communication.  However, on balance this does focus on infrastructure and capabilities.

Bullets 3 and 4 go beyond the scope of a standard focused on infrastructure and capabilities.  Both require an entity to classify the nature of the communication, as well as the initiator, recipient, and communication path.  Classifying a communication with respect to its impact on “reliable operation of the Bulk Power System” (bullet 3) or if it “could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability”(bullet 4) is highly ambiguous, subject to interpretation, and may change based on conditions.  Addressing these issues within the context of an infrastructure standard is misplaced.  Additionally, I would presume that entities would naturally consider communications capabilities that support their understood intra-functional role reliability obligations as they would be relied upon for operational purposes other than “reliability”.

Matthew Beilfuss, On Behalf of: Wisconsin Energy Corporation, RF, Segments 3, 4, 5

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COM-001-2 currently addresses communication infrastructure and capabilities between discrete functional roles (RC, TOP, BA, GOP, DP).  Bullets 1 and 2 of the project scope identify either a geographic location or specific personnel that must be defined when evaluating the adequacy of intra-functional role communication paths.  This will add some ambiguity and requires registered entity discretion when identifying the initiator and recipient of the communication.  However, on balance this does focus on infrastructure and capabilities.

 

Bullets 3 and 4 go beyond the scope of a standard focused on infrastructure and capabilities.  Both require an entity to classify the nature of the communication, as well as the initiator, recipient, and communication path.  Classifying a communication with respect to its impact on “reliable operation of the Bulk Power System” (bullet 3) or if it “could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability”(bullet 4) is highly ambiguous, subject to interpretation, and may change based on conditions.  Addressing these issues within the context of an infrastructure standard is misplaced.  Additionally, I would presume that entities would naturally consider communications capabilities that support their understood intra-functional role reliability obligations as they would be relied upon for operational purposes other than “reliability”.

Matthew Beilfuss, WEC Energy Group, Inc., 4, 7/15/2015

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Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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Jared Shakespeare, On Behalf of: Jared Shakespeare, , Segments 1

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ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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Albert DiCaprio, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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HQT support comments from  RSC-NPCC

Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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HQT supported comments from RSC of NPCC

Si Truc Phan, 7/15/2015

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Agree that the scope and objectives of the SAR addressing the Directive in Order No. 808, but disagree with the order.

Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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NPCC--Project 2015-07, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/15/2015

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NPCC--Project 2015-07, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/15/2015

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Bob Thomas, On Behalf of: Bob Thomas, , Segments 4

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We have a concern in reference to the term ‘Interpersonal Communication’. The review group feels that there is an uncertainty on the intent of the phrase ‘any medium’ within the definition. We would like to see more clarity provided on what this phrase is applicable to. Would this phrase be applicable only to real-time communication? Is it just for audible methods or does visual fit the equation? For example in Requirement R9, there is confusion on what is intended by the phrase ‘initiate action to repair or designate a replacement’. Additionally in Requirement R10, our concern would be what would be designated as a ‘medium’ in this process (when does the time start). We would suggest to the drafting team to develop some type of technical documentation that will provide clarity to both the auditor and industry. Also, we would also like to see this technical document vetted and balloted through the industry in reference to the Standard Development Process.

The review group understands that the drafting team has just recently been developed however, we would suggest coordinating efforts with the Alignment of Terms SDT (Project 2015-04). We feel that this collaborative effort would help address any definition concerns.  Additionally, we would suggest submitting a SAR to have the term included into other relevant documentation such as the Function Model, Glossary of Terms, and Rules of Procedure (RoP) to ensure that the term is properly aligned.

Finally, we would suggest some alternative language in reference to FERC’s concerns pertaining to COM-001-2….the recommended language is listed as followed:

R1.3 Reliability Coordinator control centers within the same functional entity.

R3.7 Transmission Operation control centers within the same functional entity.

R3.8 Field Personnel. 

R5.6 Balancing Authority control centers within the same functional entity.

R7.3 Distribution Provider control centers within the same functional entity.

R7.4 Distribution Provider control centers and field personnel. 

Note to drafting team: We would suggest that phrase ‘Field Personnel’ not be included into Requirement R4 or Requirement R9 for it will have unrealistic expectations in reference to Alternative Testing pertaining to Internal Communication with Field Personnel.

 

SPP Standards Review Group, Segment(s) 3, 1, 5, 7/15/2015

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Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Oshani Pathirane, 7/15/2015

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Payam Farahbakhsh, On Behalf of: Payam Farahbakhsh, , Segments 1, 3

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The SAR currently simply quotes from the FERC order and does not attempt to create a high level outline of what the standard should contain in order to give a future SDT good direction that is industry approved.  The SAR should outline some high level objectives to be met by the standard so that the industry can agree on a more defined direction before pen is put to paper to write the actual requirements.  An EXAMPLE might be:

·         The standard should outlines what communications are and are not in scope

·         The standard should requires a primary, secondary, and/or tertiary form of communications capability that are not interdependent and don’t rely on the same infrastructure

·         The standard should require each communication capability is tested on some periodic basis

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

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The SAR currently simply quotes from the FERC order and does not attempt to create a high level outline of what the standard should contain in order to give a future SDT good direction that is industry approved.  The SAR should outline some high level objectives to be met by the standard so that the industry can agree on a more defined direction before pen is put to paper to write the actual requirements.  An EXAMPLE might be:

·         The standard should outlines what communications are and are not in scope

·         The standard should requires a primary, secondary, and/or tertiary form of communications capability that are not interdependent and don’t rely on the same infrastructure

·         The standard should require each communication capability is tested on some periodic basis

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

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Occidental Chemical Corporation (OCC) believes that the Standards Authorization Request inappropriately expands the intent of FERC Order 808.  In Paragraph 41 of the Order the Commission calls for three specific updates regarding internal communications capability – these are (1) Control Center to Control Center, (2) Control Center to field personnel, and (3) other communications that could directly affect BPS reliability which are fully transacted within a single Functional Entity’s operating footprint.

The SAR also references the rule summary in Paragraph 1 of the order which is far more open ended.  In particular there was no mention of the “issuance or receipt of Operating Instructions or other communications” in the detailed ruling in Paragraph 41.  Those concepts apply to COM-002-4.

OCC believes that the rule summary presented in Paragraph 1 should be removed from the SAR so that the scope of the project is properly limited to FERC’s stated concerns.

Oxy, Segment(s) 7, 5, 7/15/2015

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Hot Answers

Venona Greaff, Oxy - Occidental Chemical, 7, 7/15/2015

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Oxy, Segment(s) 7, 5, 7/15/2015

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Other Answers

Kathy Caignon, On Behalf of: Kathy Caignon, , Segments 3

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Since a drafting team is being formed… It would be time well spent to develop a “Technical Guide” to explore the expectations of the term “INTERPERSONAL COMMUNICATION”. For example is real time communication the expectation or is it within 15 minutes, is it visual or audible communication and lastly common technologies used to achieve those goals.

Greg Froehling, On Behalf of: Rayburn Country Electric Cooperative, Inc., Texas RE, SPP RE, Segments 3, 4, 6

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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The NSRF does question the Reliability Functions applicability.  There have been other projects that have included the TO since the TO may perform actions that mimic a TOP, ie, switching.  The NSRF request that the SAR Team review this prior to the SAR going forward.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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We support the intent of the SAR and have no further comments.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 7/9/2015

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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 Does this FERC directive cover data transfer capabilities (data) as well as interpersonal communications (voice/email)?    

Scott McGough, Georgia System Operations Corporation, 3, 7/13/2015

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 Does this FERC directive cover data transfer capabilities (data) as well as interpersonal communications (voice/email)?    

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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 Does this FERC directive cover data transfer capabilities (data) as well as interpersonal communications (voice/email)?    

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Does this FERC directive cover data transfer capabilities (data) as well as interpersonal communications (voice/email)?

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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See GSOC comments.

Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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See GSOC comments

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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Molly Devine, 7/14/2015

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Molly Devine, 7/14/2015

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Molly Devine, 7/14/2015

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Lance Bean, On Behalf of: CMS Energy - Consumers Energy Company, RF, Segments 3, 4, 5

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Leonard Kula, Independent Electricity System Operator, 2, 7/14/2015

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Mark Wilson, On Behalf of: Independent Electricity System Operator - NPCC - Segments NA - Not Applicable

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ERCOT supports the comments submitted by the ISO/RTO Council Standards Review Committee.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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ERCOT supports the comments submitted by the ISO/RTO Council Standards Review Committee.

christina bigelow, 7/14/2015

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Matthew Beilfuss, On Behalf of: Wisconsin Energy Corporation, RF, Segments 3, 4, 5

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Matthew Beilfuss, WEC Energy Group, Inc., 4, 7/15/2015

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Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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Jared Shakespeare, On Behalf of: Jared Shakespeare, , Segments 1

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The SDT could enhance the clarity of the Project by replacing the phrase “internal communications” with another phrase such as “communications between personnel that are not physically co-located”. This addition would ensure that the new requirement(s) applies explicitly and only to internal communications:

  •         between geographically separate control centers within the same functional entity, or
  •        between a control center and field personnel.  

 

Although the SAR does identify these two objectives, the SAR does not limit itself to just those two objectives. This leaves the SAR ambiguous as regard to internal communications between two people sitting next to one another.  The SRC recommends that the SDT implement the revision above or other revisions to reduce the potential for ambiguity.

 

The SRC would also suggest that the phrase “adequacy of internal communications capability” be clarified. Is this phrase intended to refer to creation of a requirement that the hardware can adequately handle a conversation, or is it being used in the more generic sense that any new requirement must be adequate to address the two bullet points referenced above?

ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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The SDT could enhance the clarity of the Project by replacing the phrase “internal communications” with another phrase such as “communications between personnel that are not physically co-located”. This addition would ensure that the new requirement(s) applies explicitly and only to internal communications:

{C}·         between geographically separate control centers within the same functional entity, or

{C}·         between a control center and field personnel.  

 

Although the SAR does identify these two objectives, the SAR does not limit itself to just those two objectives. This leaves the SAR ambiguous as regard to internal communications between two people sitting next to one another.  The SRC recommends that the SDT implement the revision above or other revisions to reduce the potential for ambiguity.

 

The SRC would also suggest that the phrase “adequacy of internal communications capability” be clarified. Is this phrase intended to refer to creation of a requirement that the hardware can adequately handle a conversation, or is it being used in the more generic sense that any new requirement must be adequate to address the two bullet points referenced above?

ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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The SDT could enhance the clarity of the Project by replacing the phrase “internal communications” with another phrase such as “communications between personnel that are not physically co-located”. This addition would ensure that the new requirement(s) applies explicitly and only to internal communications:

  •     between geographically separate control centers within the same functional entity, or
  •     between a control center and field personnel.  

 

Although the SAR does identify these two objectives, the SAR does not limit itself to just those two objectives. This leaves the SAR ambiguous as regard to internal communications between two people sitting next to one another.  The SRC recommends that the SDT implement the revision above or other revisions to reduce the potential for ambiguity.

 

The SRC would also suggest that the phrase “adequacy of internal communications capability” be clarified. Is this phrase intended to refer to creation of a requirement that the hardware can adequately handle a conversation, or is it being used in the more generic sense that any new requirement must be adequate to address the two bullet points referenced above?

Albert DiCaprio, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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The SDT could enhance the clarity of the Project by replacing the phrase “internal communications” with another phrase such as “communications between personnel that are not physically co-located”. This addition would ensure that the new requirement(s) applies explicitly and only to internal communications:

{C}·         between geographically separate control centers within the same functional entity, or

{C}·         between a control center and field personnel.  

 

Although the SAR does identify these two objectives, the SAR does not limit itself to just those two objectives. This leaves the SAR ambiguous as regard to internal communications between two people sitting next to one another.  The SRC recommends that the SDT implement the revision above or other revisions to reduce the potential for ambiguity.

 

The SRC would also suggest that the phrase “adequacy of internal communications capability” be clarified. Is this phrase intended to refer to creation of a requirement that the hardware can adequately handle a conversation, or is it being used in the more generic sense that any new requirement must be adequate to address the two bullet points referenced above?

ISO Standards Review Committee, Segment(s) 2, 7/15/2015

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-Duke Energy requests further clarification from the SDT on how “adequacy” specifically, “adequacy of internal communications capability” will be measured. It is possible that what is considered adequate by one entity may not be to another, and thus could create a challenging climate to measure compliance with.

-Also, we request clarification on the usage of the term “control centers”. Is it the SDT’s intent to consider the use of the definition of “control center” from the currently effective COM-001-2 standard, or are we to consider using the definition of “Control Center” from the NERC Glossary of Terms? The terms have different definitions/meanings, and without this clarification, could result in varying interpretations throughout the industry.

-Lastly, we request clarification that the standard is only applicable to Functional Entities who operate  at the BES level. In Order 808, FERC used the term “Bulk Power System,” this could be interpreted as a changing of the applicability to sub-BES levels (below 100kV Facilities not identified as BES). If this proposed revision/new standard is to be interpreted at sub-BES levels, then would a Distribution Provider be required to maintain internal communications procedures with distribution field personnel who are not responsible for performing activities that affect the BES? Please advise as to whether the intent is to change the level of applicability.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Duke Energy requests further clarification from the SDT on how “adequacy” specifically, “adequacy of internal communications capability” will be measured. It is possible that what is considered adequate by one entity may not be to another, and thus could create a challenging climate to measure compliance with.

Also, we request clarification on the usage of the term “control centers”. Is it the SDT’s intent to consider the use of the definition of “control center” from the currently effective COM-001-2 standard, or are we to consider using the definition of “Control Center” from the NERC Glossary of Terms? The terms have different definitions/meanings, and without this clarification, could result in varying interpretations throughout the industry.

Lastly, we request clarification that the standard is only applicable to Functional Entities who operate  at the BES level. In Order 808, FERC used the term “Bulk Power System,” this could be interpreted as a changing of the applicability to sub-BES levels (below 100kV Facilities not identified as BES). If this proposed revision/new standard is to be interpreted at sub-BES levels, then would a Distribution Provider be required to maintain internal communications procedures with distribution field personnel who are not responsible for performing activities that affect the BES? Please advise as to whether the intent is to change the level of applicability.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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Si Truc Phan, 7/15/2015

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Thre is concern about the scope of this project.  Internal communications between separate control centers within the same functional entity could include communications on market issues and operational issues such as equipment status updates.  It looks like we may be going down a road requiring 3 way communications for these type of communications.   We do not believe 3 way communication is required for separate control centers within the same functional entity.  Other than what is already required for switching orders, we do not believe 3 way communication is required for communications between a control and field personnel.  Where do you draw the line for these types of communications?  If this change is for only those communications that may have an adverse effect on reliability, then the change should state "for internal communications regarding reliability directives".  Without this type of clarification, how can evidence be provided to show compliance?

Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Any requirements must be sure to directly and unequivocally address internal communications capabilities that support making a Real-time Assessment of the BES.  

NPCC--Project 2015-07, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/15/2015

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NPCC--Project 2015-07, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/15/2015

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There is a need to minimize directives to further modify NERC-approved reliability standards given the impact on compliance resources (standards development tracking, implementation of the revised standard, revision of established compliance procedures, documentation and implemenation of new internal controls, etc.). A FERC directive should be supported by information/data that there is an actual gap/problem (i.e., risk to reliability of the BES/BPS) that has occurred often enough to warrant further standards development/revision. The COM-001-2 SAR is an example of a FERC directive to address a perceived gap that does not appear to be supported by information/data that inadequate internal communications capabilities have actually produced a material risk to the BPS. If a requirement(s) specifying internal communications capabilities is deemed necessary, it should not apply to Distribution Provider.

Bob Thomas, On Behalf of: Bob Thomas, , Segments 4

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SPP Standards Review Group, Segment(s) 3, 1, 5, 7/15/2015

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N/A

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Hydro One Networks Inc. noted a few minor technicalities:

1.      In the “Purpose” section, the quoted text does not appear per verbatim out of the FERC Order, and should instead read, “internal communications capabilities to the extent that such communications could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.”

2.      In the “SAR Information” section, the quoted text does not appear per verbatim out of the FERC Order, and should instead read, “internal communications capabilities to the extent that such communications could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.

Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Hydro One Networks Inc. noted a few minor technicalities:

1.      In the “Purpose” section, the quoted text does not appear per verbatim out of the Order, and should instead read, “internal communications capabilities to the extent that such communications could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.”

2.      In the “SAR Information” section, the quoted text does not appear per verbatim out of the Order, and should instead read, “internal communications capabilities to the extent that such communications could involve the issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.

Oshani Pathirane, 7/15/2015

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Payam Farahbakhsh, On Behalf of: Payam Farahbakhsh, , Segments 1, 3

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Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

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Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

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Oxy, Segment(s) 7, 5, 7/15/2015

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