Implementation Plan for IRO Reliability Coordination Facilities Prerequisite Approvals Adoption of IRO-001-2, IRO-010-0, COM-001-2

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Prerequisite Approvals Adoption of IRO-001-2, IRO-010-0, COM-001-2 Conforming Changes to Requirements in s None Coordination with revisions proposed in other standards projects The IROL SDT proposes retiring the following requirements when IRO-010 is approved: IRO-002-2 Requirement R2 Revision Summary The RC SDT revised the standard and is proposing retiring several requirements (R1, R3, R4, R5, R6, R7 and R8). Changes were made to eliminate redundancies between standards (existing and proposed), align with NERCs Rules of Procedure and to address issues in FERC Order 693. FERC Order 693 directive for IRO-002: In addition we direct the ERO to develop a modification to through the Reliability Standards development process that requires a minimum set of tools that should be made available to reliability coordinators. RC SDT response: The development of a minimum set of tools should be addressed through the work of the Real-Time Tools Best Practices Task Force. Their charge was to develop a list of tools required to perform real time operations functions and submit SARs based on their work. As requirements for these tools are developed, appropriate standards projects will be initiated to incorporate the tools within the NERC Organization Registration and Certification Process, and the applicable reliability standards. The RC SDT submits that this directive be addressed in that effort. This action is accommodated by the Standards Development Work Plan. Functions that Must Comply with the Requirements in the Standards The requirements in IRO-002-3 are applicable to the Reliability Coordinator. Effective Dates To be determined. July 30, 2008 1

Revisions or Retirements to s The following tables identify the sections of approved standards that shall be retired or revised when this standard is implemented. If the drafting team is recommending the retirement or revision of a requirement, that text is blue. R1. Each Reliability Coordinator shall have adequate communications facilities (voice and data links) to appropriate entities within its Reliability Coordinator Area. These communications facilities shall be staffed and available to act in addressing a real-time emergency condition. [Violation Risk Factor: High] None The first sentence of this requirement should be retired because it is a basic facility issue that should be addressed in certification. The second sentence is redundant with PER-004, R1 which requires the RC to be staffed 24x7. PER-004-1 R1. Each Reliability Coordinator shall be staffed with adequately trained and NERC-certified Reliability Coordinator operators, 24 hours per day, seven days per week. Notes: The RC SDT recommends retiring this requirement. July 30, 2008 2

R2. Each Reliability Coordinator shall determine the data requirements to support its reliability coordination tasks and shall request such data from its Transmission Operators, Balancing Authorities, Transmission Owners, Generation Owners, Generation Operators, and Load-Serving Entities, or adjacent Reliability Coordinators. [Violation Risk Factor: Medium] None this requirement should be retired as it is redundant with: IRO-010-1 R1. The Reliability Coordinator shall have a documented data specification for data and information to build and maintain models to support Real-Time Monitoring, Operational Planning Analyses, and Real-Time Assessments. The specification shall include the following: (Violation Risk Factor: Low) (Time Horizon: Operations Planning) Notes: The RC SDT recommends retirement of this requirement upon implementation of IRO-010-1, R1. July 30, 2008 3

R3. Each Reliability Coordinator or its Transmission Operators and Balancing Authorities shall provide, or arrange provisions for, data exchange to other Reliability Coordinators or Transmission Operators and Balancing Authorities via a secure network. [Violation Risk Factor: Medium] [Time Horizon: Real-time Operations] None retire requirement as it is redundant with: TOP-005-1 R1. Each Transmission Operator and Balancing Authority shall provide its Reliability Coordinator with the operating data that the Reliability Coordinator requires to perform operational reliability assessments and to coordinate reliable operations within the Reliability Coordinator Area. (This requirement will be retired upon the implementation of IRO- 010-1) IRO-014-1 R1. The Reliability Coordinator shall have Operating Procedures, Processes, or Plans in place for activities that require notification, exchange of information or coordination of actions with one or more other Reliability Coordinators to support Interconnection reliability. These Operating Procedures, Processes, or Plans shall address Scenarios that affect other Reliability Coordinator Areas as well as those developed in coordination with other Reliability Coordinators. R1.1. These Operating Procedures, Processes, or Plans shall collectively address, as a minimum, the following: R1.1.1. Communications and notifications, including the conditions1 under which one Reliability Coordinator notifies other Reliability Coordinators; the process to follow in making those notifications; and the data and information to be exchanged with other Reliability Coordinators. R1.1.2. Energy and capacity shortages. R1.1.3. Planned or unplanned outage information. R1.1.4. Voltage control, including the coordination of reactive resources for voltage control. R1.1.5. Coordination of information exchange to support reliability assessments. R1.1.6. Authority to act to prevent and mitigate instances of causing Adverse Reliability Impacts to other Reliability Coordinator Areas. July 30, 2008 4

Notes: The secure network provisions of R3 are covered under the NERC Rules of Procedure, Section 1002 which states: NERC will provide tools and other support services for the benefit of reliability coordinators and other system operators, including the Area Control Error (ACE) and Frequency Monitoring System, NERC Hotline, Real-time Flows, System Data Exchange (SDX), Reliability Coordinator Information System (RCIS), Transmission Services Information Network (TSIN), Interchange Distribution Calculator (IDC), Interregional Security Network (ISN), and Central Repository for Security Events (CRC). To accomplish this goal, NERC will: 1. Maintain the reliability and effectiveness of all mission-critical operating reliability support systems and services; 2. Continue to support maintenance of a transmission provider curtailment report on the CRC site in response to Federal Energy Regulatory Commission Order 605; 3. Investigate and analyze the use of high-speed real-time system measurements, including phasors, in predicting the behavior and performance of the Eastern Interconnection; and 4. Facilitate real-time voice and data exchange services among reliability coordinators (e.g., Hotline, Interregional Security Network, NERCnet, System Data Exchange, etc.). July 30, 2008 5

R4. Each Reliability Coordinator shall have multi-directional communications capabilities with its Transmission Operators and Balancing Authorities, and with neighboring Reliability Coordinators, for both voice and data exchange as required to meet reliability needs of the Interconnection. [Violation Risk Factor: Medium] None Retire this requirement. R4 is a basic facility requirement that should be addressed in certification Notes: The RC SDT recommends retiring R4. July 30, 2008 6

R5. Each Reliability Coordinator shall have detailed real-time monitoring capability of its Reliability Coordinator Area and sufficient monitoring capability of its surrounding Reliability Coordinator Areas to ensure that potential or actual System Operating Limit or Interconnection Reliability Operating Limit violations are identified. Each Reliability Coordinator shall have monitoring systems that provide information that can be easily understood and interpreted by the Reliability Coordinator s operating personnel, giving particular emphasis to alarm management and awareness systems, automated data transfers, and synchronized information systems, over a redundant and highly reliable infrastructure. [Violation Risk Factor: High] R6. Each Reliability Coordinator shall monitor Bulk Electric System elements (generators, transmission lines, buses, transformers, breakers, etc.) that could result in SOL or IROL violations within its Reliability Coordinator Area. Each Reliability Coordinator shall monitor both real and reactive power system flows, and operating reserves, and the status of Bulk Electric System elements that are or could be critical to SOLs and IROLs and system restoration requirements within its Reliability Coordinator Area. [Violation Risk Factor: High] None Both should be retired based on the notes below. Notes: R5 is a basic facility requirement that should be addressed in certification. R6: Real-time monitoring is a supporting activity and is only one of several processes used to support operation within SOLs or IROLs. It is not practical to measure real-time monitoring, nor is this necessary. The real reliability objective is to operate within identified parameters, not to monitor. July 30, 2008 7

R7. Each Reliability Coordinator shall have adequate analysis tools such as state estimation, pre- and post-contingency analysis capabilities (thermal, stability, and voltage), and wide-area overview displays. [Violation Risk Factor: High] None Retire this requirement. Notes: The RC SDT recommends retiring Requirement R7 as it is a basic facility requirement that should be addressed in certification. July 30, 2008 8

R8. Each Reliability Coordinator shall continuously monitor its Reliability Coordinator Area. Each Reliability Coordinator shall have provisions for backup facilities that shall be exercised if the main monitoring system is unavailable. Each Reliability Coordinator shall ensure SOL and IROL monitoring and derivations continue if the main monitoring system is unavailable. [Violation Risk Factor: High] None This requirement should be retired because it is redundant with: EOP-008-0 R1. Each Reliability Coordinator, Transmission Operator and Balancing Authority shall have a plan to continue reliability operations in the event its control center becomes inoperable. The contingency plan must meet the following requirements: The contingency plan shall not rely on data or voice communication from the primary control facility to be viable. R1.2. The plan shall include procedures and responsibilities for providing basic tie line control and procedures and for maintaining the status of all inter-area schedules, such that there is an hourly accounting of all schedules. R1.3. The contingency plan must address monitoring and control of critical transmission facilities, generation control, voltage control, time and frequency control, control of critical substation devices, and logging of significant power system events. The plan shall list the critical facilities. R1.4. The plan shall include procedures and responsibilities for maintaining basic voice communication capabilities with other areas. R1.5. The plan shall include procedures and responsibilities for conducting periodic tests, at least annually, to ensure viability of the plan. R1.6. The plan shall include procedures and responsibilities for providing annual training to ensure that operating personnel are able to implement the contingency plans. R1.7. The plan shall be reviewed and updated annually. R1.8. Interim provisions must be included if it is expected to take more than one hour to implement the contingency plan for loss of primary control facility. Notes: Real-time monitoring is a supporting activity and is only one of several processes used to support operation within SOLs or IROLs. It is not practical to measure real-time monitoring, nor is this necessary. The real reliability objective is to operate within SOLs and IROLs, not to monitor. The proposed revisions to EOP-008 require the RC to have specific backup capabilities sufficient to, among other things, provide visualization capabilities that ensure that operating personnel have situational awareness of the BES. July 30, 2008 9

R9. Each Reliability Coordinator shall control its Reliability Coordinator analysis tools, including approvals for planned maintenance. Each Reliability Coordinator shall have procedures in place to mitigate the effects of analysis tool outages. [Violation Risk Factor: Medium] IRO-002-2 R2. Each Reliability Coordinator shall have a procedure to coordinate maintenance of its Reliability Coordinator analysis tools. Each Reliability Coordinator shall have procedures in place to mitigate the effects of analysis tool outages. [Violation Risk Factor: Medium] [Time Horizon: Real-time Operations, Same Day Operations and Operations Planning] Notes: The RC SDT proposes retiring the second sentence of R9 as it is redundant with EOP-008, R1 (see above). July 30, 2008 10