Unofficial Comment Form Functional Model Advisory Group Revisions to the Functional Model and Functional Model Technical Document

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1 Functional Model Advisory Group Revisions to the Functional Model and Functional Model Technical Document Do not use this form for submitting comments. Use the electronic form to submit comments on the Reliability Functional Model (FM) and the Reliability Functional Model Technical Document (FMTD). The electronic form must be submitted by 8 p.m. Eastern, Wednesday, September 7, m. Eastern, Thursday, August 20, 2015 Additional information is available on the working group page. If you have questions, contact Lacey Ourso, Standards Developer by or phone at Background Information Background regarding the Functional Model and Functional Model Technical Document The FM is a guideline that identifies the functions that must be performed to ensure that the Bulk Power System (BPS) is planned and operated in a reliable manner. The FM describes, in general terms, the functions that must be performed to ensure reliability, the specific tasks that are necessary to perform each function, and the relationships between functional entities that perform the various tasks. In its capacity of a guideline, the FM serves to provide a framework for NERC Reliability Standards as they are developed through the standard development process. The FM is independent of any particular organizational or market structure. The focus of the FM is solely on identification of reliability-related functions and the associated tasks and relationships. The FM is not a standard and does not have compliance effects. If there is a conflict between the FM and Reliability Standards, the Reliability Standards always take precedence. Also, the FM is not intended to identify the entities responsible for NERC registration. The NERC registration process is undertaken by NERC (and the Regional Entities) pursuant to authority from FERC, ultimately derived from the Federal Power Act. The FM has no authority, ability, or intent to impact or influence the NERC Registration process. The FMTD is a companion document to the FM. It serves to elaborate on the manner in which the various functional entities carry out their functions and perform their tasks. Background regarding the Functional Model Advisory Group The purpose of the Functional Model Advisory Group (FMAG), as outlined in the FMAG Scope document, is to (1) maintain the FM and FMTD to ensure the model correctly reflects the industry today, and (2) evaluate and incorporate new and emergent reliability-related tasks. The FMAG reports to the Standards Committee (SC), and works with the Planning Committee (PC), Operating Committee (OC), and Critical Infrastructure Protection Committee (CIPC) to obtain consensus regarding any proposed changes to the FM and FMTD. All proposed changes to the FM must be posted for industry comment, obtain consensus agreement from the PC, OC, and CIPC, and, ultimately, approval by the SC.

2 Overview of the 2016 FMAG project In December 2015, the FMAG began a comprehensive review and assessment of the FM and FMTD to determine if it correctly reflects the industry today and whether there was a need to incorporate any new or emerging reliability-related tasks. As a result of the review, the FMAG identified many areas in need of revision. Below is a general summary of the type and nature of the revisions proposed by the FMAG. General Overview of Proposed Revisions 1. Incorporated defined terms from the NERC Glossary of Terms: A large majority of the proposed revisions relate to incorporation of definitions from the NERC Glossary of Terms. For each proposed revision, the FMAG undertook a review to determine whether it was appropriate to incorporate the defined term, given the context and usage of the term in the FM. In some instances, the Glossary term was not used because the FMAG did not believe it had the intended meaning of the defined term, as used in the FM. In some instances, the term was simply capitalized to indicate it had the meaning of the Glossary term. In other instances, the word or phrase was replaced with a defined term (i.e., reliability-related services replaced with Interconnected Operations Service). 2. Consolidated ERO-related functions: In the current version of the FM (version 5), there are separate functions for Standards Developer, Compliance Enforcement Authority and Reliability Assurance. The FMAG believes that all of these fall under one function of ensuring the reliability of the BPS. Therefore, all functions related to reliability assurance were moved to the Reliability Assurance function. The Reliability Assurance function is intended to include any tasks performed by the Electric Reliability Organization (ERO) to ensure the reliability of the BPS, including, for example, development of Reliability Standards, development and implementation of a compliance and enforcement program, and development and maintenance of a program for identifying and registering entities responsible for compliance. 3. Clarified the planning functions: Planning Coordinator (PC), Transmission Planner (TP), and Resource Planner (RP): The proposed revisions seek to identify the differences in the various planning functions, the tasks performed by the functional entities, and how the planners work together to ensure the BES has adequate reliability planning. 4. Clarified how Interchange occurs: The proposed revisions provide clarity regarding how the various functions and functional entities work together to perform Interchange, including incorporation of appropriate Glossary terms (i.e., Requests for Interchange, Arranged Interchange, Confirmed Interchange). 5. Added cyber and physical security tasks: The FMAG is proposing to add two new tasks related to security protections for cyber assets and physical assets, and communication regarding an actual or suspected threat to those assets. The new tasks have been added to the RC, BA, TOP, TO, IC, DP, GO and GOP functions. Functional Model Advisory Group July

3 45-day informal comment period The proposed revisions to the FM and FMTD are posted for a 45-day informal comment period. The FMAG will review all comments submitted and incorporate, as appropriate, proposed revisions to the FM and FMTD. In the documents posted for comment, the highlighted language is intended to indicate that the revision relates to a substantive change. The FMAG requests that you focus your comments on these highlighted revisions. Revisions that are not deemed substantive include revisions related to: Incorporation of a Glossary term; Clarification to the existing language (i.e., use of consistent terminology); Changes to the order or manner of presentation of information (i.e., rearrangement of tasks to follow a chronological order of how the tasks are performed); Consolidation of related items or removal of redundancies; and Changes to reflect how Interchange works, including incorporation of NERC Glossary terms. Functional Model Advisory Group July

4 Questions 1. For the Reliability Assurance function: Do you agree with the proposed revisions to consolidate the ERO-related functions to the Reliability Assurance function? If not, please explain how you believe the functions related to ensuring the reliability of the Bulk Power System should be structured. Comments: Agree that consolidating the ERO Functions makes sense, however, I believe that Reliability Assurer should be a defined term in the NERC Glossary. 2. For the Reliability Assurance function: Do you agree with the proposed revisions to the Tasks and Relationships with Other Functional Entities sections? If not, please explain your specific concerns, and what revisions you propose to address those concerns. Comments: Tasks: Task 1. Within the first task, the word of and to hold them accountable is not required and recommend deletion since this is a Compliance and Enforcement issue and adequately stated in the second task (Task 2) as, has been given enforcement authority. Task 11. There is no need for specific tasks concerning Critical infrastructure Protection (task 11) as this is adequately covered by the first 10 tasks. The NSRF agrees that cyber security is important but so is every other Reliability Standard (task). The FM drives the Standard development process and the first 10 tasks address this, including cyber security. The FMAG can have a task to assure the Reliable Operation of the BPS. Believe that Regional Entities should be listed as applicable Functional Entity and included in the the Tasks for Reliability Assurance. Definition: Ok Relationship with Other Functional Entities: #3. Recommend the following, Obtains the required information, by adding required the RA would know to review specific thresholds list in Appendix 5B of the Rules of Procedures. 3. For the Planning Reliability function: Do you agree with the proposed revisions to the Tasks for the Planning Reliability function? If not, please identify the specific Task that you take issue with, Functional Model Advisory Group July

5 the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task #5 uses the term consolidated. Please define or clarify what this term means. 4. For the Planning Reliability function: Do you agree with the proposed revisions to the Introduction to the Planning Coordinator section? Please identify the specific language that you do not support, the technical basis for your position, and the alternative language that you Comments: Definition: Within the definition of PC, and Protections Systems has been added. The PC plans and coordinates information within there area of responsibility. The only task that supports Protection Systems is proposed task 4, but this task is the exchange of information only, not the details of a Protection System. Recommend Protection System be removed as it is embedded in the words of resource plans. While PCs should be aware of the protection philosophies used by its members, its role really is limited to reviewing SPS/RAS, only. Facility Owners coordinate Protection Systems. This problem spawns from NERC s glossary effort where they took every phrase (e.g. protection systems) and did a find and replace with a capitalized phrase (Protection Systems). Introduction to the Planning Coordinator: Ok 5. For the Planning Reliability function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Functional Model Advisory Group July

6 Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Relationships with Other Functional Entities for the PC: Ok 6. For the Transmission Planning function: Do you agree with the proposed revisions to the Tasks for the Transmission Planning function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Ok 7. For the Transmission Planning function: Do you agree with the proposed revisions to the Introduction to the Transmission Planner section? Please identify the specific language that you do not support, the technical basis for your position, and the alternative language that you Comments: Definition: Ok Introduction to the Transmission Planner: All BES Facilities shall be under the purview of at least one Transmission Planner. This conflicts with NERC Rules of Procedure, secton 500 which states, Ensure that all transmission Facilities of the Bulk Power System are the responsibility and under the control of one and only one Transmission Planner, Planning Authority, and Transmission Operator. Introduction to the Tranmission Planner uses the term adjoining. Other parts the FMAG also uses the term adjacent. Shouldn t this be defined and used consistent throughout? 8. For the Transmission Planning function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Functional Model Advisory Group July

7 Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Relationships with Other Functional Entities: Ok 9. For the Resource Planning function: Do you agree with the proposed revisions to the Tasks for the Resource Planning function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Ok 10. For the Resource Planning function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: : Definition: Ok Relationships with Other Functional Entities: #1. Recommend adding DP which will cover the gap of not having any registered LSEs. 11. For the Reliability Operations function: Do you agree with the proposed revisions to the Tasks for the Reliability Operations function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task 1, add assets to the end of the first task. Task 11 and 12 are not required, since task 1 states to Monitor all reliability related parameters.. The NSRF agrees that cyber security is important but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task since task 1 covers all reliability-related parameters within the reliability area. Cyber security is a sub-component of all Functional Model Advisory Group July

8 reliability-related parameters. The FMAG may add a task that states Provide Reliable Operations to assure system security. The Reliable Operations definition does contain a cybersecurity incident element. 12. For the Reliability Operations function: Do you agree with the proposed revisions to the Introduction to the Reliability Coordinator section? Please identify the specific language that you do not support, the technical basis for your position, and the alternative language that you Comments: Definition: Ok Introduction to the Reliability Coordinator: Ok 13. For the Reliability Operations function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Relationships with Other Functional Entities for Reliablitiy Coordinator: Task 2. We do not believe that every DP sends facility information to the RC but rather the BA sends facility information to the RC. Recommend that DP be replaced with BA. Task 17 recommend the directives be removed since it provides little clarity to the task. Functional Model Advisory Group July

9 14. For the Balancing function: Do you agree with the proposed revisions to the Tasks for the Balancing Authority function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: te that there is no Tasks heading are listed under Balancing Authority function but rather Balancing. There is no foot link under task 9, please place footnote 18 on page 30. Recommend task 14 and 15 be removed. The NSRF agrees that cyber security is important but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task. The FMAG may add a task that states Provide Reliable Operations to assure system security. The Reliable Operations definition does contain a cybersecurity incident element. 15. For the Balancing function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: te, this should be for the Balancing Authority function and not Balancing. Definition: Ok Tasks: Task 1. What are Facility plans? If the FMAG is looking for generation commitment (running) plans than that is what should be written. te, Task 3 covers operating statuses. Upon further review, Task 1 should be deleted due to its ambiguoulity. Task 17 is not required. Current Standard TOP-006-2, R7 requires the RC, TOP and BA to monitor frequency. They can acquire the frequency from any point within their system. Task 15 actully requires a BA to get a report of frequency regulating equipment which in itself does not support the reliable operation of the interconnection. Remember frequency regulating equipment is the actual spinning components of a generator and the speed measured to our baseline of 60hz For the Transmission Operations function: Do you agree with the proposed revisions to the Tasks for the Transmission Operations function? If not, please identify the specific Task that you Functional Model Advisory Group July

10 take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task 8. Recommend adding Recommend to the beginning of the sentence. Transmission operation can t adjust real power, but they can request adjustments. Task 11 and 12 are not needed. The NSRF agrees that cyber security is important but so is every other Reliability Standard. The FMAG seems to be updating the FM based on current enforceable NERC Standards. The FM can give a task to assure system security but not the tasks of 11 and For the Transmission Operations function: Do you agree with the proposed revisions to the Introduction to the Transmission Operator section? Please identify the specific language that you do not support, the technical basis for your position, and the alternative language that you Comments: Definition: Ok Introduction to the Transmission Operator: Ok 18. For the Transmission Operations function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Relationships with Other Functional Entities Task 1. Add the GO/GOP for coordination of blackstart resources for restoration plans. Task 7. Recommend removing the example of VAR Demand schedule. The transmsission system is designed to support the reactive power requirements developed by the TP and PC. The demand Functional Model Advisory Group July

11 for reactive power from transmission customers is decided within the TOP s interconnection agreement. Task 10. Captalized the term Curtail, however, this term in not a defined term in the NERC Glossary of Terms. 19. For the Interchange function: Do you agree with the proposed revisions to the Tasks for the Interchange Coordinator function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments:Tasks: Task 9 and 10. Task 9 and 10 are not needed. The NSRF agrees that cyber security is important but so is every other Reliability Standard. The FMAG seems to be updating the FM based on current enforceable NERC Standards. The FM can give a task to assure system security but not the tasks of 9 and For the Interchange function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Relationships with Other Functional Entities: Ok 21. For the Transmission Service function: Do you agree with the proposed revisions to the Tasks for the Transmission Service function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Ok Functional Model Advisory Group July

12 22. For the Transmission Service function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: Ok Relationships with Other Functional Entities: Task 9, 11 and 13. Uses the term Interchange Coordinator which is not a NERC defined term. Should this be changed to the term Interchange Authority which is a defined term in the NERC Glossary. Task 10. Need to clarify whether the correct term is used interchangeably is Tranmission Servive arrangenments or agreements? Task 5. The NSRF does not understand what these types of changes consist of? Pricing, MW amounts, etc? If the intent is for the TSP to tell the TOP and BA of Ancillary products, then that should be stated. But usually Ancillary products are links to a financial component and the TOP and BA may or may not elect to be part of the Ancillary markets. 23. For the Transmission Ownership function: Do you agree with the proposed revisions to the Tasks for the Transmission Ownership function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task 6 and 7. The NSRF agrees that cyber security is important but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task. 24. For the Transmission Ownership function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Functional Model Advisory Group July

13 Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: te that the TO owns and maintains transmission Facilities. They do not opertate transmission Facilities. If they do, then they need to be registered as TOPs. General Comment: agreements should be capitalized in several places since it is a NERC Glossary defined term. Relationships with Other Functional Entities: Task 5. Recommend wording update to read Develops Agreements.for jointly owned transmission n facilities Task 9. Believe the terms interconnection and agreement should both be capitalized since they are NERC defined terms. 25. For the Distribution function: Do you agree with the proposed revisions to the Tasks for the Distribution function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task 7 and 8. The NSRF agrees that cyber security is important but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task. Functional Model Advisory Group July

14 26. For the Distribution function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: Ok Introduction to the Distribution Provider: Under Introduction of the Distribution Provider, last sentence. Recommend that reclosures be deleted since the prior word of switches covers all types of devices that could be opened to shed load. Relationships with Other Functional Entities: # 8. Recommend the deletion of this task. The DP is a consumer of energy not a producer of energy. This task relates to a power producers not consumers. 27. For the Generator Operation function: Do you agree with the proposed revisions to the Tasks for the Generator Operation function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Task 6 and 7. The NSRF agrees that cyber security is important but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task. 28. For the Generator Operation function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Functional Model Advisory Group July

15 Comments: Definition: Ok Relationships with Other Functional Entities: Ahead of Time #1. Add the GO/GOP for coordination of blackstart resources for restoration plans. 29. For the Generator Ownership function: Do you agree with the proposed revisions to the Tasks for the Generator Ownership function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments:Tasks: Ok Task 5 and 6. The NSRF agrees that cyber security is but so is every other Reliability Standard. Cyber security does not need to be broken out as a specific task. When using the redline version, if a line has been removed the bullet number is not removed until you accept the change. So references to a task # don t always line up, such as GOP relationship with other functional entities line 8 on the redline is line 7 on the clean version. Functional Model Advisory Group July

16 30. For the Generator Ownership function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: Ok Relationships with Other Functional Entities: # 7, 8, 9, 10. t sure why a GO would submit a request for interchange since they only own the Facility that produces electrical power. Recommend that this task be removed. Task 11. I believe the BA will inform a GO of the power producing requirements via the IC. Recommend to change IC to BA. 31. For the Purchasing-Selling function: Do you agree with the proposed revisions to the Tasks for the Purchasing-Selling function? If not, please identify the specific Task that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Ok 32. For the Purchasing-Selling function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: Ok Relationships with Other Functional Entities: Ok 33. For the Load-Serving function: Do you agree with the proposed revisions to the Tasks for the Load-Serving function? If not, please identify the specific Task that you take issue with, the Functional Model Advisory Group July

17 technical basis for why you do not support the revisions, and the alternative language that you Comments: Tasks: Ok Functional Model Advisory Group July

18 34. For the Load-Serving function: Do you agree with the proposed revisions to the Relationships with Other Functional Entities section? If not, please identify the specific Relationship that you take issue with, the technical basis for why you do not support the revisions, and the alternative language that you Comments: Definition: Ok Relationships with Other Functional Entities: Ok 35. The FMAG is proposing to add two new Tasks related to security protections for cyber assets and physical assets, and communication regarding an actual or suspected threat to those assets. The Tasks have been added to the RC, BA, TOP, TO, IC, DP, GO and GOP functions. Do you believe there are other functional entities that also perform these tasks in carrying out their function? For example, do you believe the proposed Tasks should be included as part of the tasks performed by the Planning Coordinator? Comments: See associated comments that the protection of cyber assets is not required to be a task. The NSRF would accept assurance of system security or maintain Reliable Operations as a task, which encompasses ALL security measures that an entity can take. The NSRF agrees that cyber security is important but so is every other task that relates to an enforceable NERC Reliability Standard. 36. Do you agree with adding the two Tasks to each of the appropriate functional entities, or do you believe it is more appropriate to create a separate function (and functional entity) for the Cyberrelated tasks? Comments: See associated comments that the protection of cyber assets is not required to be a task. The NSRF would accept assurance of system security which encompasses ALL security measures that an entity can take. 37. Do you agree with the proposed revisions to the Functional Model Technical Document (FMTD)? If not, please identify the specific revisions that you do not support, the technical basis for why you do not support the revisions, and the alternative language that you propose. Comments: Page 11 of the FMTD, paragraph 4 states, Every facility must have atleast one associated Transmission Planner and at least one Planning Coordinator. NERC Rules of Procedure states, Ensure that all transmission Facilities of the Bulk Power System are the Functional Model Advisory Group July

19 responsibility and under the control of one and only one Transmission Planner, Planning Authority, and Transmission Operator. 38. If you have additional comments on the proposed revisions to the FM that you have not provided in your above responses, please provide them here: Comments: 1. Section 1, first and second sentences state, The functional model (FM) is a guideline that identifies the functions that must be performed to ensure that the Bulk Power System is planned and operated in a reliable manner. The FM describes, in general terms, the functions that must be performed to ensure reliability, the specific tasks that are necessary to perform each function, and the relationships between functional entities that perform the various tasks. If this FM is truly a guideline then there can not be mandatory functions that must be preformed. The FM is either a guide which is a process that does not need to be followed or it is the foundation document for all to follow. Recommend that the FMAG remove that must be performed. The FM sets the stage for what an Entity will be required to do predicated on the development of Reliability Standards and what functions they need to be registered for based on these functions and tasks. The FM is used within the Background section of CIP under Reliable Operations of the BES. The FM is also used in EOP (Rational for R3 section), IRO (Rational for Applicability section), to name a few. 2. Recommend to break the FM into two sections, one section relating to active (at least one Entity is registered for) Registered Functions and then section two, Other Functions so there isn t confusion that there would be standards developed for non-registered functions. 3. Recommend the removal Market Operations and Market Operator since this falls outside the scope of NERC. Commercial and financial functions fall under the responsibility of FERC within the United States. 4. The FM should be reviewed on a systematic cycle to assure that it is representing tasks that reliability functions should be accomplishing to promote system reliability. 5. In the Reliability Functional Model document, nowhere that I can find, references to the Functional Model Technical Document. It was referenced prior, but the language is now deleted due to revision. It would seem that there should be a reference of relationship between the documents. The introduction of the Technical document does provide a narrative that it is a companion document to Reliability Functional Model document. That may suffice. We were looking at the Reliability Functional Model document as the governing document and thus was looking at a relational reference from that document. 6. Pg. 1, Part 1: Foreward 2 nd and 3 rd Para. Includes the term Control Areas in caps and is not a defined term in the NERC Glossary. 7. Pg. 2, Part 2:Introduction -3 rd Para. States The work performed to meet the requirements may be selfperformed or performed by others. Recommend a clearer term for performed such as delegated be used here. Functional Model Advisory Group July

20 8. Pg. 2, Part 2:Introduction - There is some inconsistency in use of the term model or Model in the Introduction. If you are using the term Model, it should be made clear that it is being referred as The NERC Reliability Functional Model. 9. Pg. 2, Part 6:Clarification Service Since there is reference or information to what the Standard Drafting Team will need to know about the FM, I recommend that there be added to the responsibilities of the SDT in the NERC Drafting Team Reference Manual and the NERC Training modules. Functional Model Advisory Group July