WECC Position Paper for the successiveballot and non-binding poll of Project 2007-02 – Operating Personnel Communications Protocols,

beingballoted July 10-19, 2013

NERC is conductinga successiveballot of Project 2007-02 – Operating Personnel Communications Protocols, comprised of standardCOM-003-1from July 10-19, 2013.

Members of the Project 2007-02 – Operating Personnel Communications ProtocolsBallot Pool are encouraged to vote YES onCOM-003-1.

In aposition paper distributed on September 19, 2012, WECC recommended approval of COM-003-1.Initial drafts of the standard included requirements that would have promoted a consistent communication approach across the continent by identifying specific communications protocols for each Balancing Authority (BA), Reliability Coordinator (RC), and Transmission Operator (TOP). However, on April 1, 2013 WECC distributed a position paper recommending a NO vote, stating that the version being balloted March 27 – April 5, 2013 no longer addressed the reliability gaps identified in FERC Order 693 or the recommendations in the 2003 Blackout Report.

WECC staff has reviewed the most recent version, being balloted July 10-19, and concluded that the standard will promote the standardized communication protocols necessary to enhance the clarity of communications and promote bulk power system reliability. Requirement R1 now requires each BA, RC, TOP to develop documented communication protocols for the issuance of Operating Instructions. These communication protocols are subject to Reliability Coordinator approval, which helps ensure uniformity in protocols in the Reliability Coordinator’s area. Deficiencies in this area in the earlier version balloted March 27 – April 5 have been addressed.In addition the prior conflict between Requirement R1, Part 1.7 of COM-003-1, balloted March 27 – April 5, and the NERC Board of Trustees-approved version of COM-002-3 has been resolved with the clarification that COM-003-1 addresses Operating Instructions while COM-002-3 is focused on communications during emergency situations. Requirements R2 and R3 require the BA, RC, and TOP to implement its communication protocols (R2) and each BA, TOP, Generator Operator, and Distribution Provider to repeat, restate, rephrase, or recapitulate an Operating Instruction when required by the issuer of an Operating Instruction in its communications protocols (R3).

With these revisions the WECC staff recommends a YES vote on COM-003-1.

A complete copy of the proposed standard and associated materials can be viewed at:

If you determine that you will vote no, it is important that you provide a comment with your vote indicating the reason(s) why you voted no and suggested modifications that would make the standard acceptable. The NERC Reliability Standards Development Procedure requires the Operating Personnel Communications Protocolsdrafting team to consider allcomments received and conduct either another successive or recirculation ballot. Due to changes in the NERC balloting software, balloters who wish to submit comments with their ballot may no longer submit their comments from the balloting screen. Rather, those wishing to submit comments must do so via the electronic comment form available from the project page identified above.

In addition to the ballot, a non-binding poll of the Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs) is being conducted. WECC staff is not aware of any concerns with the proposed VRFs and VSLs.

If you determine that you will vote no on the non-binding poll of VRFs and VSLs, it is important that you provide a comment with your vote indicating the reason(s) why you voted no and suggested modifications that would make the VRFs/VSLs acceptable.

All WECC entities that are registered in the Project 2007-02–Operating Personnel Communications ProtocolsBallot Pool are urged to cast their ballots prior to the close of the ballot period.

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