NERC Petition for COM-001-3

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 STANDARD
COM-001-3
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

Charles A. Berardesco
Senior Vice President and General Counsel
Shamai Elstein
Senior Counsel
Candice Castaneda
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
charles.berardesco@nerc.net
shamai.elstein@nerc.net
candice.castaneda@nerc.net

Counsel for the North American Electric
Reliability Corporation

August 15, 2016

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY .................................................................................................... 2
II. NOTICES AND COMMUNICATIONS ................................................................................ 4
III. BACKGROUND .................................................................................................................... 4
A. Regulatory Framework ..................................................................................................... 4
B. NERC Reliability Standards Development Procedure ..................................................... 5
C. Procedural History of Proposed Reliability Standard COM-001-3 ................................. 6
1. History of COM-001-2.1 and Order No. 808 .......................................................... 6
2. Project 2015-07 Internal Communications Capabilities .......................................... 9
IV. JUSTIFICATION FOR APPROVAL..................................................................................... 9
A. Proposed Reliability Standard COM-001-3 and Applicable Entities ............................. 10
B. Justification for Proposed Reliability Standard COM-001-3 and Revisions .................. 11
C. Enforceability of Proposed Reliability Standard COM-001-3 ........................................ 12
V. EFFECTIVE DATE .............................................................................................................. 13
VI. CONCLUSION ..................................................................................................................... 14
Exhibit A

Proposed Reliability Standard COM-001-3

Exhibit B

Implementation Plan

Exhibit C

Order No. 672 Criteria

Exhibit D

Mapping Document

Exhibit E

Analysis of Violation Risk Factors and Violation Severity Levels

Exhibit F

Summary of Development History and Complete Record of Development

Exhibit G

Standard Drafting Team Roster

i

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 STANDARD COM-001-3
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 2 the
North American Electric Reliability Corporation (“NERC”) 3 hereby requests Commission
approval of proposed Reliability Standard COM-001-3 (Communications) (Exhibit A), the
associated Implementation Plan (Exhibit B), retirement of currently-effective Reliability
Standard COM-001-2.1, and the Violation Risk Factors (“VRFs”) and Violation Severity Levels
(“VSLs”) associated with new Requirements R12 and R13 proposed in Reliability Standard
COM-001-3 (Exhibit E). Proposed Reliability Standard COM-001-3 reflects revisions
developed under Project 2015-07 Internal Communications Capabilities, in compliance with the
Commission’s directive in Order No. 808 that NERC, “develop modifications to COM-001-2, or
[to] develop a new standard, to address [the Commission’s] concerns regarding ensuring the
adequacy of internal communications capability whenever internal communications could
directly affect the reliable operation of the Bulk-Power System.” 4 The NERC Board of Trustees
adopted proposed Reliability Standard COM-001-3 on August 11, 2016.

1

16 U.S.C. § 824o (2012).
18 C.F.R. § 39.5 (2016).
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
Order No. 808, Communications Reliability Standards, 151 FERC ¶ 61,039, 80 Fed. Reg. 22385 (2015) (to
be codified at 15 C.F.R. pt. 40) at P 41 (2015). See also, id., at P 1 (stating, “the Commission directs that NERC
develop one modification to Reliability Standard COM-001-2 that addresses internal communications capabilities to
the extent that such communications could involve the issuance or receipt of Operating Instructions or other
2

1

NERC requests that the Commission approve proposed Reliability Standard COM-001-3,
with its new Requirements R12 and R13, as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. NERC also requests that the Commission accept the
proposed Implementation Plan, retirement of Reliability Standard COM-001-2.1, and VRFs and
VSLs for new Requirements R12 and R13, all effective on the first day of the first calendar
quarter that is 9 months after the effective date of the Commission’s order approving the
standard. On this effective date, proposed Reliability Standard COM-001-3 will supersede and
replace COM-001-2.1.
As required by Section 39.5(a) of the Commission’s regulations, 5 this petition presents
the technical basis and purpose of proposed Reliability Standard COM-001-3, summarizes the
development history (Exhibit F), and demonstrates that the proposed Reliability Standard meets
the criteria identified by the Commission in Order No. 672 (Exhibit C).6
I.

EXECUTIVE SUMMARY
In approving Reliability Standard COM-001-2, the Commission “direct[ed] NERC to

develop modifications to COM-001-2, or to develop a new standard, to address our concerns
regarding ensuring the adequacy of internal communications capability whenever internal
communications could directly affect the reliable operation of the Bulk-Power System.” 7 NERC

communications that could have an impact on reliability.”). 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.
5
18 C.F.R. § 39.5(a) (2016).
6
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 PP 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
7
See, Order No. 808, at P 41.

2

developed Requirements R12 and R13 in proposed Reliability Standard COM-001-3 to address
this directive.
Proposed Requirements R12 and R13 address internal communication capabilities
whenever such communications could directly affect reliable operation of the Bulk-Power
System (including through communications within functional entities). NERC’s proposed
revisions require that, consistent with the Commission’s directive, responsible entities maintain
internal Interpersonal Communication capabilities for the exchange of information necessary for
Reliable Operation of the Bulk Electric System (“BES”) (this includes, for example,
communication capabilities between control centers and field personnel). These Requirements
enhance reliability by clearly encompassing internal Interpersonal Communications within the
scope of Reliability Standard COM-001-3.
NERC respectfully requests that the Commission approve proposed Reliability Standard
COM-001-3, the associated Implementation Plan, and VRFs/VSLs for Requirements R12 and
R13, as consistent with the directive in Order No. 808 and just, reasonable, not unduly
discriminatory or preferential, and in the public interest.

3

II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the

following: 8
Shamai Elstein*
Senior Counsel
Candice Castaneda*
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, DC 20005
(202) 400-3000
shamai.elstein@nerc.net
candice.castaneda@nerc.net

III.

Howard Gugel*
Director of Standards
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
Howard.Gugel@nerc.net

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005, 9 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 Electric Reliability Organization (“ERO”) that
would be charged with developing and enforcing mandatory Reliability Standards, subject to
Commission approval. Section 215(b)(1) of the FPA states that all users, owners, and operators
of the Bulk-Power System in the United States will be subject to Commission-approved
Reliability Standards. 10 Section 215(d)(5) of the FPA authorizes the Commission to order the
ERO to submit a new or modified Reliability Standard. 11 Section 39.5(a) of the Commission’s

8

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 (2016), to allow the inclusion
of more than two persons on the service list in this proceeding.
9
16 U.S.C. § 824o (2012).
10
Id. § 824o(b)(1).
11
Id. § 824o(d)(5).

4

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. 12
The Commission is vested with 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 FPA 13 and Section 39.5(c) of the
Commission’s regulations, “the Commission will give due weight to the technical expertise of
the Electric Reliability Organization” with respect to the content of a Reliability Standard. 14
B.

NERC Reliability Standards Development Procedure

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process. 15 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual. 16

12

18 C.F.R. § 39.5(a) (2016).
16 U.S.C. § 824o(d)(2) (2012).
14
18 C.F.R. § 39.5(c)(1) (2016).
15
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.”).
16
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.
13

5

In its order certifying NERC as the Commission’s ERO, 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 Standards, 17 and thus
satisfy certain of the criteria for approving Reliability Standards. 18 The development process is
open to any person or entity with a legitimate interest in the reliability of the Bulk-Power
System. NERC considers the comments of all stakeholders, and stakeholders must approve, and
the NERC Board of Trustees must adopt a Reliability Standard before the Reliability Standard is
submitted to the Commission for approval.
C.

Procedural History of Proposed Reliability Standard COM-001-3

As described below, standard drafting team designed proposed Reliability Standard to
include two new requirements on internal Interpersonal Communication capabilities in
compliance with the Commission’s directive in Order No. 808. This section summarizes the
history leading to development of proposed Reliability Standard COM-001-3.
1.

History of COM-001-2.1 and Order No. 808

NERC originally implemented Reliability Standard COM-001-0 (Telecommunications)
on April 1, 2005. This version sought to ensure coordinated telecommunications among
operating entities, and was submitted in NERC’s 2006 petition for approval of proposed
Reliability Standards. 19 Prior to commission approval, Reliability Standard COM-001-0 was
later revised and replaced by COM-001-1 to include certain missing compliance elements. In
Order No. 693, the Commission approved Reliability Standard COM-001-1, while issuing
directives to improve the standard, including a directive to include Generator Operators and

17

N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 at P 250.
Order No. 672 at PP 268, 270.
19
North American Electric Reliability Council & North American Electric Reliability Corp's CD containing
its petition for approval of reliability standards, Docket No. RM06-16-000 (filed Apr. 4, 2006).
18

6

Distribution Providers as applicable entities and identify specific requirements for
telecommunications facilities. 20 An errata to the standard was accepted in 2009, resulting in
Reliability Standard COM-001-1.1.
Subsequently, NERC developed further revisions to comply with the directives in Order
No. 693 and improve the standard. 21 In 2014, NERC filed Reliability Standard COM-001-2 to
improve COM-001-1.1 and comply with remaining Commission directives in Order No. 693. 22
Reliability Standard COM-001-2 established a clear set of requirements for the communications
capabilities that various functional entities must maintain for reliable communications. On April
16, 2015, in Order No. 808, the Commission approved Reliability Standard COM-001-2, new
definitions associated with the revisions, VRFs and VSLs for COM-001-2, and the proposed
Implementation Plan. The Commission also directed a modification to Reliability Standard
COM-001-2 to address “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.” 23 The Commission found that while
Reliability Standard COM-001-2 would enhance reliability, it was not persuaded that the
standard adequately covered all situations in which Operating Instructions are issued or
received. 24

20

Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 Fed. Reg. 16416, FERC
Stats. & Regs. ¶ 31,242, PP 487-93, 502-04, 508, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
21
See, Petition of the North American Electric Reliability Corporation for Approval of Proposed Reliability
Standards COM-001-2 and COM-002-4, Docket No. RM14-13-000, at Section IV.A. and C, and Section V.A (filed
May 14, 2014) (including more detailed history).
22
Id. (reflecting that the petition also included Reliability Standard COM-002-4 (Operating Personnel
Communications Protocols)).
23
Order No. 808, at P 1.
24
Id. at P 3.

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In particular, the Commission explained that Requirement R1.1 of the prior version of the
standard better addressed internal Interpersonal Communication capabilities. The Commission
stated that Requirement R1.1 of COM-001-1.1 provided that “each reliability coordinator,
transmission operator, and balancing authority ‘shall provide adequate and reliable
telecommunication facilities for the exchange of Interconnection and operating information . . .
internally.’” 25 The Commission provided that even though Reliability Standard COM-001-2
applies to communications between functional entities within a single organization, Requirement
R1.1 of COM-001-1.1 was broader by explicitly applying to internal communications within the
same functional entity. 26 As a result, the Commission determined:
Thus, unlike the currently-effective Reliability Standard, COM-001-2 does not
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. These scenarios
present a gap in reliability of the Bulk-Power System that NERC should address.
Accordingly, pursuant to section 215(d)(5) of the FPA, we direct NERC to
develop modifications to COM-001-2, or to develop a new standard, to address
our concerns regarding ensuring the adequacy of internal communications
capability whenever internal communications could directly affect the reliable
operation of the Bulk-Power System. 27
NERC subsequently filed an errata to COM-001-2 to reflect typographical corrections, resulting
in currently-effective Reliability Standard COM-001-2.1. 28

25

Id. at P 41.
Id. at PP 41-42.
27
Id. at P 41.
28
Errata to Petitions of NERC for Approval of Reliability Standards BAL-003-1, COM-001-2, VAR-001-4,
and Implementation Plan for Reliability Standard PRC-004-4, Docket No. RD15-6-000 (filed Aug. 25, 2015).
26

8

2.

Project 2015-07 Internal Communications Capabilities

NERC established Project 2015-07 Internal Communications Capabilities upon the
Commission’s issuance of Order No. 808, to comply with the Commission’s directive to address
internal communications capability, whenever such communications could directly affect
Reliable Operation of the Bulk-Power System. 29 In order to achieve this goal, proposed
Reliability Standard COM-001-3 incorporates two new Requirements R12 and R13, detailed in
Section IV below. These two Requirements explicitly address internal Interpersonal
Communication capabilities. The proposed standard is intended to replace and retire Reliability
Standard COM-001-2.1, consistent with the Implementation Plan.
IV.

JUSTIFICATION FOR APPROVAL
As discussed below and in Exhibit C, proposed Reliability Standard COM-001-3 satisfies

the Commission’s criteria in Order No. 672 and is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. The following subsections provide: (A) a description of
the proposed standard, its reliability purposes, and applicable entities; (B) justification for the
proposed Reliability Standard, detailing the proposed revisions; and (C) discussion of the
enforceability of the proposed Reliability Standard. As discussed herein, the revised standard
complies with Commission’s directive in Order No. 808 for development of “modifications to
COM-001-2, or … a new standard, to address [the Commission’s] concerns regarding ensuring
the adequacy of internal communications capability whenever internal communications could
directly affect the reliable operation of the Bulk-Power System.” 30

29

See, Standard Authorization Request, available at
http://www.nerc.com/pa/Stand/Project%20201507%20Internal%20Communications%20Capabilitie/201507_Internal_Comm_Cap_SAR_06112015.pdf.
30
Id. at P 41.

9

A.

Proposed Reliability Standard COM-001-3 and Applicable Entities

The purpose of proposed Reliability Standard COM-001-3 is “[t]o establish Interpersonal
Communication capabilities necessary to maintain reliability.” 31 The proposed standard revises
Reliability Standard COM-001-2.1 pursuant to the Commission’s directive in Order No. 808, by
adding new Requirements R12 and R13 to expressly require applicable entities to “have internal
Interpersonal Communication capabilities for the exchange of information necessary for the
Reliable Operation of the BES. This includes communication capabilities between Control
Centers within the same functional entity, and/or between a Control Center and field
personnel.” 32
The standard applies to Transmission Operators, Balancing Authorities, Reliability
Coordinators, Distribution Providers, and Generator Operators. These are the same entities
currently subject to Reliability Standard COM-001-2.1. Inclusion of Distribution Providers and
Generator Operators is also consistent with revisions made in Reliability Standard COM-001-2
to comply with the Commission’s directive in Order No. 693 that the standard should apply to
Generator Operators and Distribution Providers. 33

31

See Exhibit A, attached herein
See, proposed Requirements R12 and R13. In Requirement R13, control center is not capitalized as it is a
Distribution Provider control center. As reflected in the Rationale supporting Requirement R13, in Requirement
R13 “control center is intended to mean the Distribution Provider facilities hosting operating personnel performing
the operational functions of the Distribution Provider that are necessary for the reliable operation of the BES, often
referred to as a distribution control center, or distribution center. Examples of Distribution Providers exchanging
information necessary for the Reliable Operation of the BES include Distribution Providers included in restoration
plans, load shed plans, load reconfiguration, and voltage control plans. The Distribution Provider must have the
capability to exchange information whenever the internal Interpersonal Communications may directly impact
operations of the BES.”
33
See e.g., Order No. 693, at PP 487-493.
32

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B.

Justification for Proposed Reliability Standard COM-001-3 and Revisions

The revisions described herein and reflected at Requirements R12 and R13 of COM-0013 are as follows: 34
R12.
Each Reliability Coordinator, Transmission Operator, Generator Operator,
and Balancing Authority shall have internal Interpersonal Communication
capabilities for the exchange of information necessary for the Reliable Operation of
the BES. This includes communication capabilities between Control Centers within
the same functional entity, and/or between a Control Center and field personnel.
[Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M12. Each Reliability Coordinator, Transmission Operator, Generator Operator,
and Balancing Authority shall have and provide upon request evidence that it has
internal Interpersonal Communication capability, which could include, but is not
limited to:
•
physical assets, or
•
dated evidence, such as, equipment specifications and installation
documentation, operating procedures, test records, operator logs, voice
recordings, transcripts of voice recordings, or electronic communications.
R13.
Each Distribution Provider shall have internal Interpersonal
Communication capabilities for the exchange of information necessary for the
Reliable Operation of the BES. This includes communication capabilities between
control centers within the same functional entity, and/or between a control center
and field personnel. [Violation Risk Factor: Medium] [Time Horizon: Real-time
Operations]
M13. Each Distribution Provider shall have and provide upon request evidence
that it has internal Interpersonal Communication capability, which could include,
but is not limited to:
•
physical assets, or
•
dated evidence, such as, equipment specifications and installation
documentation, operating procedures, test records, operator logs, voice
recordings, transcripts of voice recordings, or electronic communications.
These modifications will explicitly require applicable entities to have internal
Interpersonal Communication capabilities, in compliance with the Commission’s directive in
Order No. 808. As discussed in Section III.C above, in Order No. 808, the Commission was
concerned that Reliability Standard COM-001-2 did not adequately address the adequacy of
internal telecommunications. The proposed Requirements would ensure that Reliability
34

See Exhibit A for full redline (the redline also includes edits to match NERC’s Standard template, such as
moving measures near the revelant requirements).

11

Standard COM-001-3 clearly addresses internal Interpersonal Communications capabilities that
could involve the issuance or receipt of Operating Instructions or other communications that
could directly impact reliability. This would include, for example, internal Interpersonal
Communications capabilities for control centers within the same functional entity (including
geographically separate control centers ) and/or between a control center and field personnel. 35
The proposed Requirements are also drafted to ensure sufficient flexibility to allow for
differences among individual entities regarding internal communications (such as different
technologies or communication protocols arising due to different organizational structures) and
avoid creating criteria that would be impractical and unnecessary. 36 As a result, the proposed
Requirements strike a balance between ensuring that the standard expressly addresses internal
Interpersonal Communications capabilities while retaining sufficient flexibility to effectuate
communications and should be approved as just, reasonable, and in the public interest.
C.

Enforceability of Proposed Reliability Standard COM-001-3

The Proposed Reliability Standard includes 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 Standard also includes VRFs and
VSLs for each Requirement. The VSLs and VRFs are part of several elements used to determine

35

Note that in Order No. 808, the Commission stated that it “agree[d] with NERC and other commenters that
Reliability Standard COM-001-2 applies to communications between functional entities within a single
organization…. However, the application of COM-001-2 to different functional entities within the same
organization, as discussed above, does not fully address our concern set forth in the NOPR regarding internal
communications… unlike the currently-effective Reliability Standard, COM-001-2 does not 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. These scenarios present a gap in reliability of the Bulk-Power System that NERC should address.
Accordingly, pursuant to section 215(d)(5) of the FPA, we direct NERC to develop modifications to COM-001-2, or
to develop a new standard, to address our concerns regarding ensuring the adequacy of internal communications
capability whenever internal communications could directly affect the reliable operation of the Bulk-Power
System.” See, Order No. 808, at PP 40-41.
36
See, id., at P 53.

12

an appropriate sanction when the associated Requirement is violated. The VSLs provide
guidance on the way that NERC will enforce the Requirements of the proposed Reliability
Standards. The VRFs assess the impact to reliability of violating a specific Requirement.
NERC proposes updates to the VRFs and VSLs in effect for COM-001-2.1 to include the
appropriate VRFs and VSLs for proposed Requirements R12 and R13. Requirement R12
(applicable to Reliability Coordinators, Transmission Operators, Generator Operators, and
Balancing Authorities) has been assigned a “High” VRF and Requirement R13 (applicable to
Distribution Providers) has been assigned a “Medium” VRF. These VRFs are consistent with
the VRFs applicable to these functional entities under existing Requirements in Reliability
Standard COM-001-2. In addition, both Requirements R12 and R13 have a “Severe” VSL
because they are “binary” requirements. Exhibit E includes detailed analysis of the assignment
of VRFs and the VSLs for proposed Requirements R12 and R13. As reflected in Exhibit E, the
VRFs and VSLs for the new Requirements in proposed Reliability Standard comport with NERC
and Commission guidelines.
V.

EFFECTIVE DATE
NERC respectfully requests that the Commission accept proposed Reliability Standard

COM-001-3 effective on the first day of the first calendar quarter that is 9 months after the
effective date of the Commission’s order approving the standard. This effective date should
provide sufficient time for applicable entities to incorporate any additional necessary
infrastructure to effectuate compliance with Requirements R12 and R13 (including Generator
Operators and Distribution Providers, which had not been responsible for compliance with
Reliability Standard COM-001-1.1, Requirement R1.1). 37 In addition, NERC requests

37

Supra, n. 20 and 33.

13

retirement of Reliability Standard COM-001-2.1 immediately prior to the Effective Date of
COM-001-3, as the standard will replace and supersede currently-effective Reliability Standard
COM-001-2.1.
VI.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve (i)

proposed Reliability Standard COM-001-3 with new Requirements R12 and R13 and other
associated elements included in Exhibit A; (ii) the Implementation Plan included in Exhibit B;
(iii) the retirement of currently-effective Reliability Standard COM-001-2.1, and (iv) the VRFs
and VSLs for new Requirements R12 and R13 included in Exhibit E.

Respectfully submitted,
/s/ Candice Castaneda
Charles A. Berardesco
Senior Vice President and General Counsel
Shamai Elstein
Senior Counsel
Candice Castaneda
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
charles.berardesco@nerc.net
shamai.elstein@nerc.net
candice.castaneda@nerc.net
Counsel for the North American Electric
Reliability Corporation

Date: August 15, 2016

14